Employers v. Not Employers

Office of Chief Counsel
Internal Revenue Service
Memorandum
Number: 200519075
Release Date: 5/13/2005
CC:TEGE:EOEG:ET1
POSTN-165915-04
UILC: 3231.01-00 date: September 30, 2003 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 businesses are not employers 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 the
RRB, we also conclude that ---and ---are not employers under the Railroad Retirement Tax Act. Please take the appropriate action regarding these businesses.
Will E. McLeod
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