Ezel / IRS Rulings / 200645021

CCA 200645021: Railroad retirement tax coverage ended for a business

Number
200645021
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Employers v. Not Employers
Topics
Employment taxes
Code sections
§ 3231
Ruling dated
July 10, 2006
Publicly released
November 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.

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 had ceased being a covered employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act. Chief Counsel reviewed the Board's opinion and agreed that the business had ceased to be covered under the Railroad Retirement Tax Act as well. The public letter redacts the business name and effective date. It asks the IRS submission processing office to take the appropriate action for the business.

Ruling snapshot

  • Question: Had the business ceased to be a covered employer under the Railroad Retirement Tax Act?
  • Outcome: Advice given: coverage ended on a redacted date.
  • Key authorities: Railroad Retirement Tax Act; IRC § 3231.

Full text (IRS public release)

Office of Chief Counsel

Memorandum
Internal Revenue Service

Number: 200645021
Release Date: 11/10/06
CC:TEGE:EOEG:ET1
POSTN-123982-06

UILC: 3231.01-00

date: July 10, 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 ceased being a covered employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective close of business -------------
-----------------------------------------------------------------
-----------------------
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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 the ------------------------------------------------------------- ------------- ceased to be a covered employer under the jurisdiction of 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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