Ezel / IRS Rulings / 200714019

CCA 200714019: Railroad business treated as an employer for tax purposes

Number
200714019
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Employers v. Not Employers
Topics
Employment taxes
Code sections
§ 3231
Ruling dated
January 9, 2007
Publicly released
April 6, 2007
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 2007, 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 2007
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 redacted business had become an employer under the Railroad Retirement Act and Railroad Unemployment Insurance Act. IRS Chief Counsel reviewed the Board's opinion and agreed that the business had become an employer under the Railroad Retirement Tax Act. The effective date and business identity were redacted. Counsel asked the IRS processing unit to act on that conclusion.

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; IRC § 3231.

Full text (IRS public release)

Office of Chief Counsel

Memorandum
Internal Revenue Service

Number: 200714019
Release Date: 4/6/2007
CC:TEGE:EOEG:ET1
POSTN-156826-06

UILC: 3231.01-00

date: January 09, 2007
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 effective ----------------------. Please take the appropriate action regarding this business.

____
Janine Cook

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