Ezel / IRS Rulings / 200148046

CCA 200148046: Two businesses became railroad tax employers in October 2000

Number
200148046
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Employers v. Not Employers
Topics
Employment taxes
Code sections
§ 3231
Ruling dated
September 5, 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 that two businesses became employers under the railroad retirement and unemployment laws on October 1, 2000. IRS counsel reviewed the board's opinion and agreed that both became employers under the Railroad Retirement Tax Act on that date. Counsel asked the IRS service center to take appropriate action. The released memo redacts the businesses' identities and does not set out the underlying classification facts.

Ruling snapshot

  • Question: When did the two businesses become railroad tax employers?
  • Outcome: Advice given: both became employers on October 1, 2000.
  • Key authorities: Railroad Retirement Tax Act; IRC § 3231.

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

SEP 05, 2001

Number: 200148046
Release Date: 11/30/2001
CC:TEGE:EOEG:ET1 - COR-131230-01
UILC: 3231.01-00

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-131230-01
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 the following businesses became employers under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective October 1, 2000:

We have reviewed the opinion of the RRB and, based upon the information submitted to the RRB, we also conclude that
and
became employers
under the Railroad Retirement Tax Act effective October 1, 2000. Please take the appropriate action regarding these businesses.

Will E. McLeod

cc:

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