Employers v. Not Employers

Office of Chief Counsel
Internal Revenue Service
Memorandum
Number: 200518072
Release Date: 5/6/2005
CC:TEGE:EOEG:ET1
POSTN-161043-04
UILC: 3231.01-00 date: January 4, 2005 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 became 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 ---became an employer under the Railroad Retirement Tax Act effective ---. We assume the reference in the RRB opinion that the prior company and its assets were sold to ------owner is not intended to indicate the same entity merely changed names. Please take the appropriate action regarding this business.
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Janine Cook cc: