Ezel / IRS Rulings / 9933009

CCA 9933009: IRS concurs with two railroad employer status conclusions

Number
9933009
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Employers v. Not Employers
Topics
Employment taxes
Code sections
§ 3231
Ruling dated
May 5, 1999
Publicly released
August 20, 1999
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 1999, 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 1999
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 sent the IRS an opinion on employer status under the Railroad Retirement Act and Railroad Unemployment Insurance Act. Based solely on the information submitted, the IRS concurred that one redacted entity was not an employer and another became an employer under those Acts. The public copy omits the entities' names and the effective date. This classification affects the railroad employment tax rules associated with section 3231.

Ruling snapshot

  • Question: Did the IRS agree with the Board's employer status conclusions?
  • Outcome: Advice given; the IRS concurred based solely on the submitted information.
  • Key authorities: IRC § 3231; Railroad Retirement Act; Railroad Unemployment Insurance Act.

Full text (IRS public release)

DEPARTMENT OF THE TREASURY
I N T E R N AL R E V E N U E S E R V I C E WASHINGTON, D.C. 20224

MAY 5 1999

UILC: 3231.01-00
CC:EBEO:6
Number: 199933009
Release Date: 8/20/1999
MEMORANDUM FOR

FROM: Chief, Branch 6, Office of the Associate Chief Counsel
(Employee Benefits and Exempt Organizations)

SUBJECT:
Railroad Retirement Act Tax Status

Attached for your information and appropriate action is a copy of a letter from the
Railroad Retirement Board concerning the status under the Railroad Retirement Act
and the Railroad Unemployment Insurance Act of:

We have reviewed the opinion of the Railroad Retirement Board and, based solely
upon the information submitted, concur in the conclusion that is not an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act. We further concur in the conclusion

that
is an employer under the Railroad
Retirement Act and the Railroad Unemployment Insurance Act effective

HARRY BEKER
2

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