CCA 200731033: Railroad business ceased to be a covered employer

Number

200731033

Outcome

Advice

Document type

Chief Counsel Advice

IRS subject

Employers v. Not Employers

Topics

Employment taxes

Code sections

§ 3231

Ruling dated

December 13, 2006

Publicly released

August 3, 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.

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 ceased to be an employer under the railroad retirement and unemployment insurance laws. Chief Counsel reviewed that opinion and the information the Board supplied. It agreed that the business had ceased to be an employer for Railroad Retirement Tax Act purposes and asked the IRS processing unit to take appropriate action. The effective date is redacted in the public memorandum.

Ruling snapshot

Question: Did the business cease to be an employer for Railroad Retirement Tax Act purposes?
Outcome: Chief Counsel agreed that employer status had ended on the redacted effective date.
Key authorities: IRC § 3231; Railroad Retirement Tax Act.

Full text (IRS public release)

Office of Chief Counsel

Memorandum
Internal Revenue Service

Number: 200731033
Release Date: 8/3/2007
CC:TEGE:EOEG:ET1
POSTN-148076-06

UILC: 3231.01-00

date: December 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 that the following business ceased being 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 being an employer under the Railroad Retirement Tax Act effective ---------------- -------. Please take the appropriate action regarding this business.

_____
Janine Cook

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