Employers v. Not Employers

Office of Chief Counsel
Internal Revenue Service
Memorandum
Number: 200518076
Release Date: 5/6/2005
CC:TEGE:EOEG:ET1
POSTN-164268-04
UILC: 3231.01-00 date: January 23, 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 is not an employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act and service performed by its employees is not covered employee service 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 ---is not an employer under the Railroad Retirement Tax Act, and service performed by its employees is not covered employee service under the Act. Please take the appropriate action regarding this business.
Joseph W. Spires cc: