CCA 200546040: Railroad employer name change reported without identification number

Number
200546040
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Employers v. Not Employers
Code sections
§ 3231
Ruling dated
August 3, 2005
Publicly released
November 18, 2005

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 sent the IRS notice of a name change for a covered railroad employer. The memorandum tells the IRS processing office that no Employer Identification Number was provided and asks it to take appropriate action. The public release redacts the employer's identity and the effective date of the name change.

Ruling snapshot

  • Question: What should the IRS processing office do with the Board's notice of a covered employer's name change?
  • Outcome: Advice given: take appropriate action on the name change notice.
  • Key authorities: Railroad Retirement Tax Act; UILC 3231.01-00.

Full text (IRS public release)

Office of Chief Counsel

Memorandum
Internal Revenue Service

Number: 200546040
Release Date: 11/18/2005
CC:TEGE:EOEG:ET1
POSTN-125392-05

UILC: 3231.01-00

date: August 3, 2005
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 a notice announcing a name change of a covered employer effective -------------------, for the following:

-------------------------------
-----------------------------------------------------------------------------
----------------------------------------------
---------------------------------------------------
--------------------------------------------------------------------------
------------------------------------------------

An Employer Identification Number was not provided. Please take the appropriate action regarding this business.

_____
Janine Cook
cc----------------

What does the Code say today, for your facts?

This advice was written for IRS staff and cannot be cited. Ezel checks the current Internal Revenue Code and IRS guidance against your situation, with citations.

Opens in Ezel Pro.

  • Checks the law as it stands today, not only this page
  • Cites every source it relies on, so you can verify it
  • Chat, drafting and research in one workspace