Ezel / IRS Rulings / 200210016

CCA 200210016: Railroad employer status begins July 25, 2000

Number
200210016
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Employers v. Not Employers
Topics
Employment taxes
Code sections
§ 3231
Ruling dated
November 28, 2001
Publicly released
March 8, 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

After reviewing a Railroad Retirement Board reconsideration, IRS Chief Counsel concluded that a redacted business became an employer under the Railroad Retirement Tax Act on July 25, 2000, rather than February 13, 2001. The memorandum directed a service center to take appropriate action. The released text gives no details about the business or the reasoning behind the changed date.

Ruling snapshot

  • Question: When did the business become an employer under the Railroad Retirement Tax Act?
  • Outcome: Advice: employer status began July 25, 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

NOV 28, 2001

Number: 200210016
Release Date: 3/8/2002
UILC: 3231.01-00
GENIN-146017-01/CC:TEGE:EOEG:ET1

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 - GENIN-146017-01
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 of a reconsideration that the following business became an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective July 25, 2000 instead of February 13, 2001:

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 July 25, 2000. Please take the appropriate action regarding this business.

Will E. McLeod

cc:

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