Ezel / IRS Rulings / 200518075

CCA 200518075: Businesses ceased to be railroad tax employers

Number
200518075
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Employers v. Not Employers
Topics
Employment taxes
Ruling dated
February 11, 2004
Publicly released
May 6, 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 advised the IRS that several businesses had ceased to be employers under the Railroad Retirement Act and Railroad Unemployment Insurance Act. Chief Counsel agreed that the businesses also ceased to be employers under the Railroad Retirement Tax Act as of the specified effective date. The IRS release redacts the businesses' identities and that date, and gives no additional explanation of their operations.

Ruling snapshot

  • Question: Did the businesses remain employers under the Railroad Retirement Tax Act?
  • Outcome: Advice given: their employer status ended on a redacted date.
  • Key authorities: Railroad Retirement Tax Act.

Full text (IRS public release)

Office of Chief Counsel

Memorandum
Internal Revenue Service

Number: 200518075
Release Date: 5/6/2005

CC:TEGE:EOEG:ET1
POSTN-164265-04

UILC: 3231.01-00

date: February 11, 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 businesses ceased to be employers under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective ------------------:

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We have reviewed the opinion of the RRB and, based upon the information submitted to us by the RRB, we also conclude that ------------------------------------------------------------------ --------------------------------------------------------------------------------------------------and ------------- -----------------ceased to be employers under the Railroad Retirement Tax Act effective --- ------------------. Please take the appropriate action regarding these businesses.

Joseph W. Spires cc:

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