Ezel / IRS Rulings / 200825040

CCA 200825040: Railroad employer status ended with compensated service

Number
200825040
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Employers v. Not Employers
Topics
Employment taxes
Code sections
§ 3231
Ruling dated
March 18, 2008
Publicly released
June 20, 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 reported that a business's status as a covered employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act had ended. IRS counsel reviewed the Board's opinion and concluded that the business's covered employer status ended on the last date employees were compensated because operations had terminated. Counsel directed the IRS processing office to take appropriate action. The business's identity and the date were redacted from the public memorandum.

Ruling snapshot

  • Question: When did the business's covered railroad employer status end?
  • Outcome: It ended on the last date employees were compensated following termination of operations.
  • Key authorities: Railroad Retirement Act; Railroad Unemployment Insurance Act.

Full text (IRS public release)

Office of Chief Counsel

Memorandum
Internal Revenue Service

Number: 200825040
Release Date: 6/20/2008
CC:TEGE:EOEG:ET1
POSTN-103269-08

UILC: 3231.01-00

date: March 18, 2008
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 status of the following business as a covered employer under the jurisdiction of the Railroad Retirement Act and the Railroad Unemployment Insurance Act ended 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 status of ----------------------------------- as a covered employer under the jurisdiction of the Railroad Retirement Act, ended on -------- ---------------------------, the last date on which employees were compensated due to termination of operations.

POSTN-103269-08
2

Please take the appropriate action regarding this business.

_____
Janine Cook

cc:

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