Ezel / IRS Rulings / 9941031

CCA 9941031: Counsel concurs that an entity ceased to be a railroad employer

Number
9941031
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Employers v. Not Employers
Topics
Employment taxes
Ruling dated
July 16, 1999
Publicly released
October 15, 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 IRS received a Railroad Retirement Board opinion about whether an entity remained an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act. Based solely on the information submitted, Chief Counsel concurred with the opinion that the entity had ceased to be an employer under both Acts. The entity's name and effective date are redacted from the public release. The memorandum gives no further facts or legal analysis.

Ruling snapshot

  • Question: Did the entity cease to be an employer under the two railroad Acts?
  • Outcome: Advice: based solely on the information submitted, Chief Counsel concurred with the Board's conclusion that it did.
  • 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 16 1999

UILC: 3231.01-00
COR-108980-99
Number: 199941031
CC:EBEO:6
Release Date: 10/15/1999

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 ceased to be an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective

HARRY BEKER

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