Ezel / IRS Rulings / 200148047

CCA 200148047: Railroad employer status changed for two businesses

Number
200148047
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 one business became an employer under the railroad retirement and unemployment laws on February 9, 2001, while another ceased to be an employer that day. IRS counsel reviewed the board's opinion and agreed with those dates for Railroad Retirement Tax Act purposes. The memo notes that the two businesses had the same address and contact person. Their names and the underlying classification facts are redacted from the released letter.

Ruling snapshot

  • Question: What were the railroad tax employer status dates for the two businesses?
  • Outcome: Advice given: one became an employer and the other ceased to be one on February 9, 2001.
  • 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: 200148047
Release Date: 11/30/2001
CC:TEGE:EOEG:ET1 - COR-131274-01
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-131274-01
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 became an employer under the Railroad
Retirement Act and the Railroad Unemployment Insurance Act effective February 9,
2001, and that
ceased to be an employer under
the Acts effective February 9, 2001. Both businesses have the same address and contact person:

We have reviewed the opinion of the RRB and, based upon the information submitted to the RRB, we also conclude that became an employer under the Railroad Retirement Tax Act effective February
9, 2001, and that
ceased to be an employer
under the Act effective February 9, 2001. Please take the appropriate action regarding these businesses.

Will E. McLeod

cc:

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