Employers v. Not Employers

Office of Chief Counsel
Internal Revenue Service
Memorandum
Number: 200709061
Release Date: 3/2/2007
CC:TEGE:EOEG:ET1
POSTN-146766-06
UILC: 3231.01-00 date: November 16, 2006 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, we also conclude that ---. ceased to be an employer under the Railroad Retirement Tax Act effective ---, the date on which it was purchased by a non-railroad employer and was no longer owned by or under common control with a rail carrier employer. Please take the appropriate action regarding this business.
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Janine Cook
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