Employers v. Not Employers

Office of Chief Counsel
Internal Revenue Service
Memorandum
Number: 200512009
Release Date: 3/25/05
CC:TEGE:EOEG:ET1:
POSTN-161872-04
UILC: 3231.01-00 date: July 23, 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 that the following business is not an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act:
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We have reviewed the opinion of the RRB and, based upon the information submitted to us by the RRB, we also conclude that ---is not an employer under the Railroad Retirement Tax Act. We do not have enough information to determine whether any workers performing services for ---may be employees of another entity, including an entity that may be a rail carrier. Please take the appropriate action regarding this business.
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Janine Cook cc: