Employers v. Not Employers

Office of Chief Counsel
Internal Revenue Service
Memorandum
Number: 200514016
Release Date: 4/8/2005
CC:TEGE:EOEG:ET1:
POSTN-161866-04
UILC: 3231.01-00 date: August 4, 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 ceased to be an 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 also conclude that ---ceased to be an employer under the Railroad Retirement Tax Act (RRTA) effective ---. However, we similarly note that the entity’s obligations to file the appropriate returns and pay the appropriate taxes under the RRTA for periods prior to such date are not extinguished by this change in status. Please take the appropriate action regarding this business.
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Janine Cook cc---