CCA 200606036: Business ceased to be a railroad tax employer

Number

200606036

Outcome

Advice

Document type

Chief Counsel Advice

IRS subject

Employers v. Not Employers

Topics

Employment taxes

Code sections

§ 3231

Ruling dated

November 18, 2005

Publicly released

February 10, 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 told the IRS that a business had ceased to be an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act. Chief Counsel reviewed the Board's opinion and, based on the information it provided, concluded that the business had also ceased to be an employer under the Railroad Retirement Tax Act. The memorandum asks the IRS processing office to take the appropriate action. The business's identity and the effective date are redacted.

Ruling snapshot

Question: Had the business ceased to be an employer for Railroad Retirement Tax Act purposes?
Outcome: Advice that it had ceased to be an employer as of a redacted date.
Key authorities: Railroad Retirement Tax Act; IRC § 3231 (index classification).

Full text (IRS public release)

Office of Chief Counsel

Memorandum
Internal Revenue Service

Number: 200606036
Release Date: 2/10/2006
CC:TEGE:EOEG:ET1
POSTN-148332-05

UILC: 3231.01-00

date: November 18, 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 dated
--------------------------, that the following business ceased to be an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective with the close of business 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 to be an employer under the Railroad Retirement Tax Act on --------------------------. Please take the appropriate action regarding this business.
____
Janine Cook

cc:

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