Employers v. Not Employers

Office of Chief Counsel
Internal Revenue Service
Memorandum
Number: 200514014
Release Date: 4/8/2005
CC:TEGE:EOEG:ET1:
POSTN-161860-04
UILC: 3231.01-00 date: August 04, 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 reconsideration of a prior opinion that the following business is not a covered 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 a covered employer under the Railroad Retirement Tax Act. We do not have enough information to determine whether any of the workers providing services to --- 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--