Ezel / IRS Rulings / 200651032

CCA 200651032: Business ceased to be a railroad retirement tax employer

Number
200651032
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Employers v. Not Employers
Topics
Employment taxes
Code sections
§ 3231
Ruling dated
September 19, 2006
Publicly released
December 22, 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 notified the IRS that a business had ceased to be an employer under the Railroad Retirement Act and Railroad Unemployment Insurance Act. Chief Counsel reviewed the Board's opinion and submitted information. It likewise concluded that the business had ceased to be an employer under the Railroad Retirement Tax Act. The effective timing and final compensation date are redacted. The memorandum directs the IRS entity unit to take appropriate action without providing further factual or legal analysis.

Ruling snapshot

  • Question: Does the business remain an employer under the Railroad Retirement Tax Act?
  • Outcome: Advice given: the business ceased to be a railroad retirement tax employer.
  • Key authorities: Railroad Retirement Tax Act; IRC § 3231 (indexed employer-status provision).

Full text (IRS public release)

Office of Chief Counsel

Memorandum
Internal Revenue Service

Number: 200651032
Release Date: 12/22/06
CC:TEGE:EOEG:ET1
POSTN-139597-06

UILC: 3231.01-00

date: September 19, 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 ceased to be 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 ------------------------------------------ceased to be an employer under the Railroad Retirement Tax Act in -------, with compensation last paid on ---------------------------. Please take the appropriate action regarding this business.

____
Janine Cook

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