Ezel / IRS Rulings / 200148026

CCA 200148026: Railroad employer status transfers between two businesses

Number
200148026
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Employers v. Not Employers
Topics
Employment taxes
Code sections
§ 3231
Ruling dated
August 27, 2001
Publicly released
November 30, 2001
Source
View Official PDF

Apply this to your situation

This page covers legal advice the IRS Office of Chief Counsel wrote for IRS staff, issued in 2001, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Currency note: this determination was released in 2001
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It is advice from the IRS Office of Chief Counsel to IRS personnel on the facts they presented, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

The Railroad Retirement Board advised the IRS that one redacted business was a railroad employer from April 1 through December 13, 2000, and another became an employer on December 13, 2000. IRS counsel reviewed the Board's opinion and the information submitted to it. Counsel reached the same conclusions for employer status under the Railroad Retirement Tax Act and directed a service center to take appropriate action. The memorandum gives no further facts about the businesses.

Ruling snapshot

  • Question: When did each business have employer status under the Railroad Retirement Tax Act?
  • Outcome: Advice given; one period ended and the other began on December 13, 2000.
  • Key authorities: Railroad Retirement Tax Act; Railroad Retirement Act; Railroad Unemployment Insurance Act.

Full text (IRS public release)

DEPARTMENT OF THE TREASURY
I N T E R N AL R E V E N U E S E R V I C E WASHINGTON, D.C. 20224

AUG 27 2001

Number: 200148026
Release Date: 11/30/2001
UILC: 3231.01-00
CC:TEGE:EOEG:ET1 - COR-126664-01

MEMORANDUM FOR DIRECTOR, INTERNAL REVENUE SERVICE CENTER Kansas City, MO
Attn: Entity Control

FROM: Office of Division Counsel/Associate Chief Counsel
(Tax Exempt and Government Entities)

SUBJECT: CC:TEGE:EOEG:ET1 - COR-126664-01
Railroad Retirement Act Tax Status

In accordance with the coordination procedure established between the Service and
the Railroad Retirement Board (RRB), the RRB has provided us with its opinion that was an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act (the Acts), from April 1, 2000 until December 13, 2000; and that became an employer under the Acts effective December 13,
2000. The name and address of the contact official for both taxpayers is:

We have reviewed the opinion of the RRB and, based upon the information
submitted to the RRB, we also conclude that was an employer under the Railroad Retirement Tax Act (RRTA) from April 1, 2000 until December 13, 2000; and that became an employer under the RRTA effective December 13, 2000. Please take the appropriate action regarding these businesses.

Will E. McLeod

cc:

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