Employers v. Not Employers

Office of Chief Counsel
Internal Revenue Service
Memorandum
Number: 200804021
Release Date: 1/25/2008
CC:TEGE:EOEG:ET1
POSTN-137530-07
UILC: 3231.01-00 date: October 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 that the following business became a rail carrier employer under the jurisdiction of 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 ---became a rail carrier under the jurisdiction of the Railroad Retirement Tax Act, effective ---, the date it received, by transfer, the assets and operating agreement rights of ------, a rail carrier.
Please take the appropriate action regarding this business.
____
Janine Cook cc: