Ezel / IRS Rulings / 200604031

CCA 200604031: IRS concurs that business became a railroad employer

Number
200604031
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Employers v. Not Employers
Topics
Employment taxes
Code sections
§ 3231
Ruling dated
October 20, 2005
Publicly released
January 27, 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.

Currency note: this determination was released in 2006
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 a business became an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act. After reviewing the Board's opinion and supporting information, the IRS agreed that the business became an employer under the Railroad Retirement Tax Act. Chief Counsel directed the IRS processing unit to take the appropriate action. The public document redacts the business's identity and the effective date.

Ruling snapshot

  • Question: Did the business become an employer under the Railroad Retirement Tax Act?
  • Outcome: Advice given: the IRS agreed with the Railroad Retirement Board's employer status finding.
  • 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: 200604031
Release Date: 1/27/2006
CC:TEGE:EOEG:ET1
POSTN-144127-05

UILC: 3231.01-00
date: Oct. 20, 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 became an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act 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 ---------------------------became an employer under the Railroad Retirement Tax Act on ---------------------. Please take the appropriate action regarding this business.

_____
Janine Cook

Cc: Mr. Wayne Van Dyck
Internal Revenue Service
210 1st ST., Suite 500
Roanoke, VA 24011-1605

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