Ezel / IRS Rulings / 9936043

CCA 9936043: Railroad services credited as employee service

Number
9936043
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Employers v. Not Employers
Topics
Employment taxes
Code sections
§ 3231
Ruling dated
July 15, 1999
Publicly released
September 10, 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

Chief Counsel reviewed a Railroad Retirement Board opinion about whether a person's work could be credited as railroad service for benefit entitlement. Based solely on the information submitted, it agreed that the person performed the services as an employee. The memorandum says the services are creditable under the Railroad Retirement Act and the Railroad Unemployment Insurance Act. It does not describe the underlying work or the Board's reasoning.

Ruling snapshot

  • Question: Were the redacted person's services employee service creditable under the two railroad benefit laws?
  • Outcome: Advice given: Chief Counsel concurred with the Railroad Retirement Board's conclusion that the services were creditable.
  • Key authorities: 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

JUL 15 1999

UILC: 3231.01-00
COR:107724-99
Number: 199936043
CC:EBEO:6
Release Date: 9/10/1999

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 whether the services performed by
for
may be credited as
railroad services for purposes of determining benefit entitlement under the Railroad Retirement Act and the Railroad Unemployment Insurance Act.

We have reviewed the opinion of the Railroad Retirement Board and, based solely upon the information submitted, concur in the conclusion that the services performed by for were performed as an employee and are creditable under the Railroad Retirement Act and the Railroad Unemployment Insurance Act.

HARRY BEKER

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