Ezel / IRS Rulings / 200642002

CCA 200642002: Chief Counsel confirms railroad employer status

Number
200642002
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Employers v. Not Employers
Topics
Employment taxes
Code sections
§ 3231
Ruling dated
July 13, 2006
Publicly released
October 20, 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. Chief Counsel reviewed the Board's opinion and the information it submitted. The memo concluded that the same business became an employer under the Railroad Retirement Tax Act and asked IRS processing staff to take appropriate action. The business's identity and effective date are redacted from the public release.

Ruling snapshot

  • Question: Did the business become an employer under the Railroad Retirement Tax Act?
  • Outcome: Advice given; Chief Counsel agreed with the Railroad Retirement Board's employer classification.
  • Key authorities: Railroad Retirement Tax Act; UILC 3231.01-00.

Full text (IRS public release)

Office of Chief Counsel

Memorandum
Internal Revenue Service

Number: 200642002
Release Date: 10/20/2006
CC:TEGE:EOEG:ET1
POSTN-127203-06

UILC: 3231.01-00

date: July 13, 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 dated
------------------, 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 on -----------------------. Please take the appropriate action regarding
this business.

Janine Cook

cc:

What does the Code say today, for your facts?

This advice was written for IRS staff and cannot be cited. Ezel checks the current Internal Revenue Code and IRS guidance against your situation, with citations.

Opens in Ezel Pro.

  • Checks the law as it stands today, not only this page
  • Cites every source it relies on, so you can verify it
  • Chat, drafting and research in one workspace