Employers v. Not Employers

Office of Chief Counsel
Internal Revenue Service
Memorandum
Number: 200509021
Release Date: 3/4/2005
CC:TEGE:EOEG:ET1
POSTN-160147-04
UILC: 3231.01-00 date: October 20, 2004 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 dated
---, that the following business became a rail carrier employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective ------:
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We have reviewed the opinion of the RRB and, based upon the information submitted to us by the RRB, we agree with the RRB’s determination that --- became a rail carrier employer under the Railroad Retirement Tax Act on ------.
However, we note that the submitted facts indicate that the entity’s representative states the entity has no employees. Please take the appropriate action regarding this business.
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Janine Cook cc: