Ezel / IRS Rulings / 200633028

CCA 200633028: Business treated as a Railroad Retirement Tax Act employer

Number
200633028
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Employers v. Not Employers
Topics
Employment taxes
Code sections
§ 3231
Ruling dated
May 11, 2006
Publicly released
August 18, 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 an unnamed business had become an employer under two railroad benefit laws as of a redacted date. IRS Chief Counsel reviewed the Board's opinion and the information it supplied. Counsel agreed that the business became an employer under the Railroad Retirement Tax Act on that date and asked the processing unit to take appropriate action. The public letter does not disclose the business's identity or the effective date.

Ruling snapshot

  • Question: Is the business an employer under the Railroad Retirement Tax Act?
  • Outcome: Advice given: it became an employer as of the redacted date.
  • Key authorities: Railroad Retirement Tax Act, IRC § 3231.

Full text (IRS public release)

Office of Chief Counsel
memorandum
Internal Revenue Service

CC:TEGE:EOEG:ET1
POSTN-116259-06

UILC: 3231.01-00
Number: 200633028
Release Date: 8/18/2006

date: May 11, 2006
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 as of --------------------------:

-----------------------------------------------
--------------------------------------------------
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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 as of --------------------------.
Please take the appropriate action regarding this business.

_____
Janine Cook
cc:

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