Ezel / IRS Rulings / 200604032

CCA 200604032: IRS accepts railroad employer status determination

Number
200604032
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 told the IRS that a business had become an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act. The IRS reviewed that opinion and the submitted information. It reached the same conclusion under the Railroad Retirement Tax Act and directed its processing unit to take the appropriate action. The business identity and effective date are redacted in the public release.

Ruling snapshot

  • Question: Did the business become an employer under the Railroad Retirement Tax Act?
  • Outcome: Advice given: the IRS concluded that it had and directed processing action.
  • 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: 200604032
Release Date: 1/27/2006
CC:TEGE:EOEG:ET1
POSTN-144129-05

UILC: 3231.01-00
date: October 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 effective -------------------:

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

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 effective -------------------. Please take the appropriate action regarding this business.

__________
Janine Cook
cc: ----------------------------
----------------------------------------

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