CCA 200601025: Rail carrier ceased to be a covered employer

Number

200601025

Outcome

Advice

Document type

Chief Counsel Advice

IRS subject

Employers v. Not Employers

Topics

Employment taxes

Code sections

§ 3231

Ruling dated

August 3, 2005

Publicly released

January 6, 2006

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 2006, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

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 a business had ceased to be a covered rail carrier employer under the railroad retirement and unemployment statutes. Chief Counsel reviewed the Board's information and agreed that the business had ceased to be a covered employer under the Railroad Retirement Act on a redacted date. The memorandum, headed “Railroad Retirement Tax Act Status,” asks the IRS processing unit to take appropriate action. The business and effective date are redacted.

Ruling snapshot

Question: Had the business ceased to be a covered rail carrier employer?
Outcome: Advice given; Chief Counsel agreed it had ceased on the redacted date.
Key authorities: Railroad Retirement Act; Railroad Unemployment Insurance Act; Railroad Retirement Tax Act (memorandum subject).

Full text (IRS public release)

Office of Chief Counsel

Memorandum
Internal Revenue Service

Number: 200601025
Release Date: 1/6/2006
CC:TEGE:EOEG:ET1
POSTN-137098-05
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 its opinion that the following business ceased being a covered rail carrier employer under the jurisdiction of the Railroad Retirement and Railroad Unemployment Insurance Acts on --------------------
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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 --------------------------------------------. ceased being a covered rail carrier employer under the Railroad Retirement Act on -----------------. Please take the appropriate action regarding this business.

_____
Janine Cook

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