Ezel / IRS Rulings / 200751026

CCA 200751026: Business is outside railroad retirement tax employer coverage

Number
200751026
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Employers v. Not Employers
Topics
Employment taxes
Code sections
§ 3231
Ruling dated
September 18, 2007
Publicly released
December 21, 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 business was not a covered employer under the Railroad Retirement Act or the Railroad Unemployment Insurance Act. After reviewing the board's opinion and the information it supplied, the Office of Chief Counsel agreed that the business was not a covered employer under the Railroad Retirement Tax Act. It asked the IRS submission processing office to take appropriate action. The released memorandum does not give details about the business's operations.

Ruling snapshot

  • Question: Is the business a covered employer for Railroad Retirement Tax Act purposes?
  • Outcome: Advice given; it is not a covered employer.
  • Key authorities: Railroad Retirement Tax Act; Railroad Retirement Act; Railroad Unemployment Insurance Act.

Full text (IRS public release)

Office of Chief Counsel

Memorandum
Internal Revenue Service

Number: 200751026
Release Date: 12/21/2007
CC:TEGE:EOEG:ET1
POSTN-133242-07

UILC: 3231.01-00

date: Sept. 18, 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 that the following business is not a covered employer under the jurisdiction of the Railroad Retirement Act and the Railroad Unemployment Insurance Act:

-----------------------------------------
-----------------------------------------
-------------------------------------------------
-----------------------------------------------

We have reviewed the opinion of the RRB and, based upon the information submitted to us by the RRB, we also conclude that the ------------------------------------------is not a covered employer under the jurisdiction of the Railroad Retirement Tax Act.

Please take the appropriate action regarding this business.

_____
Janine Cook
cc: ----

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