Ezel / IRS Rulings / 200203028

CCA 200203028: Railroad retirement coverage had ended

Number
200203028
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Employers v. Not Employers
Topics
Employment taxes
Ruling dated
October 17, 2001
Publicly released
January 18, 2002
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 2002, 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 2002
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 coverage of a redacted business under the Railroad Retirement Act had terminated effective February 23, 1998. After reviewing the Board's opinion and the information submitted to it, Chief Counsel reached the same conclusion. The memorandum directed an IRS service center to take the appropriate action for that business. It provides no further facts about the business or explanation of the coverage determination.

Ruling snapshot

  • Question: Had Railroad Retirement Act coverage of the business ended?
  • Outcome: Advice given that coverage terminated February 23, 1998.
  • Key authorities: Railroad Retirement Board opinion referenced in the memorandum.

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

OCT 17, 2001

Number: 200203028
Release Date: 1/18/2002
CC:TEGE:EOEG:ET1 - COR-140358-01
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-140358-01
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 coverage of the following business terminated effective February 23, 1998:

We have reviewed the opinion of the RRB and, based upon the information submitted to the RRB, we also conclude that coverage of , terminated effective
February 23, 1998. Please take the appropriate action regarding this business.

Will E. McLeod

cc:

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