Ezel / IRS Rulings / 200948046

CCA 200948046: Revenue Ruling 58-599 treats the United States government as one employer

Number
200948046
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Wages
Topics
Employment taxes
Code sections
§ 3121, § 6110
Publicly released
November 27, 2009
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 2009, 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 2009
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

This Chief Counsel Advice addresses whether the United States government is one employer for purposes of the wage rules. Counsel points to Revenue Ruling 58-599, which states that the federal government is one employer, while noting that the ruling does not specifically address the wage base. The advice also notes that Revenue Ruling 58-599 cites a Comptroller General opinion that would apply.

Ruling snapshot

  • Question: Does the United States government constitute one employer under the wage rules?
  • Outcome: Advice given
  • Key authorities: IRC § 3121; Rev. Rul. 58-599; Comptroller General opinion

Full text (IRS public release)

ID: CCA_2009101516360232 Number: 200948046
Release Date: 11/27/2009
Office: -----------------------------
UILC: 3121.01-00

From: --------------------
Sent: Thursday, October 15, 2009 4:36:05 PM
To: ----------------------
Cc:
Subject: Federal Government as One Employer

-----------

As we discussed, there is a Revenue Ruling that indicates that the United States government is one employer. It is Revenue Ruling 58-599. It does not specifically deal with the wage base, but it does say the US government is one employer. The Rev Rul also cites a Comptroller General Opinion that would apply. I hope this is helpful.

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

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