CCA 200601027: Railroad employer status ended by a redacted date

Number

200601027

Outcome

Advice

Document type

Chief Counsel Advice

IRS subject

Employers v. Not Employers

Topics

Employment taxes

Code sections

§ 3231

Ruling dated

September 29, 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 ceased to be a railroad employer under the railroad retirement and unemployment statutes. Based on the Board's information, Chief Counsel concluded that the business also ceased to be an employer under the Railroad Retirement Tax Act no later than a redacted date. The Board reported that operations had ended, but did not provide the last date on which compensation was paid. The memorandum asks the IRS processing unit to take appropriate action.

Ruling snapshot

Question: When did the business cease to be a Railroad Retirement Tax Act employer?
Outcome: Advice given; it ceased to be an employer no later than the redacted date.
Key authorities: Railroad Retirement Tax Act; Railroad Retirement Act; Railroad Unemployment Insurance Act.

Full text (IRS public release)

Office of Chief Counsel

Memorandum
Internal Revenue Service

Number: 200601027
Release Date: 1/6/2006
CC:TEGE:EOEG:ET1
POSTN-140673-05
UILC: 3231.01-00

date: September 29, 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 to be an employer 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 -------------------------------------ceased to be an employer under the Railroad Retirement Tax Act effective no later than ----------------. We note that the RRB’s opinion indicated that -------------------------------------ceased operations at the end of -------. No information was provided as to the last date compensation was paid. Please take the appropriate action regarding this business.

__________
Janine Cook

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