Ezel / IRS Rulings / 200151016

CCA 200151016: Railroad employer status changed for three businesses

Number
200151016
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Employers v. Not Employers
Topics
Employment taxes
Code sections
§ 3231
Ruling dated
September 17, 2001
Publicly released
December 21, 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 business became a railroad employer on March 3, 2001, while two others ceased to be railroad employers on March 2, 2001. After reviewing the Board's opinion and the information submitted to it, Chief Counsel reached the same conclusions under the Railroad Retirement Tax Act. The memorandum asked an IRS service center to update its records for the three businesses. Their names were removed from the public release.

Ruling snapshot

  • Question: Which of the three businesses were employers under the Railroad Retirement Tax Act, and when did their status change?
  • Outcome: Advice given: one became an employer on March 3, 2001; two ceased to be employers on March 2, 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 17, 2001

Number: 200151016
Release Date: 12/21/2001
CC:TEGE:EOEG:ET1 - COR-137341-01
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-137341-01
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 March 3,
2001, and that
and
both ceased to be employers under the Acts effective March 2, 2001. All three businesses have the same contact person and address:

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 March 3,
2001. We also conclude that and
ceased being employers under the Act effective March 2, 2001.
Please take the appropriate action regarding these businesses.

                                                            Will E. McLeod

cc:

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