Ezel / IRS Rulings / 200804020

CCA 200804020: IRS confirms end of a business's railroad tax employer status

Number
200804020
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Employers v. Not Employers
Topics
Employment taxes
Code sections
§ 3231
Ruling dated
October 18, 2007
Publicly released
January 25, 2008
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 2008, 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 2008
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 ceased to be an employer under the railroad retirement and unemployment insurance laws on a redacted date. IRS counsel reviewed the board's opinion and the information submitted. Counsel reached the same conclusion for the Railroad Retirement Tax Act, effective on the redacted date, and instructed the IRS entity unit to take the appropriate action. The released memorandum gives no further explanation for the change in status.

Ruling snapshot

  • Question: Did the business cease to be an employer under the Railroad Retirement Tax Act?
  • Outcome: Advice that employer status ended on the redacted date.
  • Key authorities: IRC § 3231.

Full text (IRS public release)

Office of Chief Counsel

Memorandum
Internal Revenue Service

Number: 200804020
Release Date: 1/25/2008
CC:TEGE:EOEG:ET1
POSTN-137529-07

UILC: 3231.01-00

date: October 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 ceased to be an employer under the jurisdiction of the Railroad Retirement Act and the Railroad Unemployment Insurance Act on -------------------------:

------------------------------------------------------------------------------
---------------------------
-----------------------------------------
----------------------------------------
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 an employer under the Railroad Retirement Tax Act, on --------------------------.

Please take the appropriate action regarding this business.

_____
Janine Cook
cc: --------------------------------------------

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