Employers v. Not Employers

Office of Chief Counsel
Internal Revenue Service
Memorandum
Number: 200751027
Release Date: 12/21/2007
CC:TEGE:EOEG:ET1
POSTN-133243-07
UILC: 3231.01-00 date: September 18, 2007 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 became an employer 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 us by the RRB, we also conclude that ---became an employer under the Railroad Retirement Tax Act on ---when it began operations. We do not know when it began compensating employees. Please take the appropriate action regarding this business.
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Janine Cook cc:---