Ezel / IRS Rulings / 200152022

CCA 200152022: Business found outside Railroad Retirement Tax Act employer status

Number
200152022
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Employers v. Not Employers
Topics
Employment taxes
Code sections
§ 3231, § 6110
Ruling dated
September 27, 2001
Publicly released
December 28, 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 told the IRS that a redacted business was not an employer under the Railroad Retirement Act or the Railroad Unemployment Insurance Act. IRS counsel reviewed that opinion and the information submitted to the Board. It agreed that the business was not an employer under the Railroad Retirement Tax Act and asked the IRS service center to take appropriate action. The public memorandum gives no further facts about the business or its activities.

Ruling snapshot

  • Question: Was the business an employer under the Railroad Retirement Tax Act?
  • Outcome: Advice given: IRS counsel concluded that it was not an employer.
  • Key authorities: IRC § 3231; 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

SEP 27, 2001

Number: 200152022
Release Date: 12/28/2001
CC:TEGE:EOEG:ET1 - COR-137334-01
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-137334-01
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 business is not an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act:

We have reviewed the opinion of the RRB and, based upon the information submitted to the RRB, we also conclude that is not an employer under the Railroad Retirement Tax Act. Please take the appropriate action regarding this business.

Will E. McLeod

cc:

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