Ezel / IRS Rulings / 200514017

CCA 200514017: IRS accepts railroad board finding that a business ceased to be an employer

Number
200514017
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Employers v. Not Employers
Topics
Employment taxes
Code sections
§ 3231
Ruling dated
June 29, 2004
Publicly released
April 8, 2005
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 2005, 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 2005
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 business had ceased to be an employer under the Railroad Retirement Act and Railroad Unemployment Insurance Act. After reviewing the board's opinion and the information it supplied, Chief Counsel reached the same conclusion for Railroad Retirement Tax Act purposes. The memorandum asks the IRS processing unit to take appropriate action. The business's identity and the effective date are redacted in the public release.

Ruling snapshot

  • Question: Had the business ceased to be an employer under the Railroad Retirement Tax Act?
  • Outcome: Advice given: the IRS concluded that it had, effective on a redacted date.
  • Key authorities: Railroad Retirement Tax Act; IRC § 3231.

Full text (IRS public release)

Office of Chief Counsel

Memorandum
Internal Revenue Service

Number: 200514017
Release Date: 4/8/2005
CC:TEGE:EOEG:ET1:
POSTN-161890-04

UILC: 3231.01-00

date: June 29, 2004
to: Director, Submission Processing
Cincinnati, OH
Attn: Entity Unit

from: Office of Division Counsel/Associate Chief Counsel Tax Exempt & Government Entities

subject: Railroad Retirement Tax Act 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 ceased to be an employer under the Railroad Retirement Act and the
Railroad Unemployment Insurance Act effective -------------------:
-------------------------------------------------------------------------
---------------------------------------------------------------------
--------------------------------------------------------
---------------------------------------------------------
We have reviewed the opinion of the RRB and, based upon the information submitted to
us by the RRB, we also conclude that ------------------------------------------------------------------
----------- ceased to be an employer under the Railroad Retirement Tax Act effective -----
-------------------. Please take the appropriate action regarding this business.

_____
Janine Cook

cc:

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