Employers v. Not Employers

Office of Chief Counsel
Internal Revenue Service
Memorandum
Number: 200513025
Release Date: 4/1/2005
CC:TEGE:EOEG:ET1:
POSTN-161886-04
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 that two of the following businesses became employers under the Railroad Retirement Act and the Railroad Unemployment Insurance Act effective ---, and that one business is not an employer under the Acts:
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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 ------and ------became employers under the Railroad Retirement Tax Act effective ---. We also conclude that ---is not an employer under the Act. Please take the appropriate action regarding these businesses.
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Janine Cook