Employers v. Not Employers

Office of Chief Counsel
Internal Revenue Service memorandum
Number: 200543055
Release Date: 10/28/2005
CC:TEGE:EOEG:ET1
POSTN-125377-05
UILC: 3231.01-00 date: July 13, 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 dated
---, 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 and our subsequent phone conversation with the taxpayer, we believe that ---merely changed its name, effective ---, after it became affiliated with the ------
- ---. The new name with the ---is ---
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---. --
--- is a division within ---.
POSTN-125377-05 2
Please take the appropriate action regarding this business.
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Janine Cook cc: ---
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