Employers v. Not Employers

Office of Chief Counsel
Internal Revenue Service
Memorandum
Number: 200513024
Release Date: 4/1/2005
CC:TEGE:EOEG:ET1:
POSTN-161884-04
UILC: 3231.01-00 date: June 30, 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 concerning the following business 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 work preformed through ------as a locomotive engineer or as a conductor for a covered rail employer is employee service for the rail carrier employer under the Railroad Retirement Tax Act. Please take the appropriate action regarding this business.
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Janine Cook-