Employers v. Not Employers

Office of Chief Counsel
Internal Revenue Service
Memorandum
Number: 200807014
Release Date: 2/15/2008
CC:TEGE:EOEG:ET1
POSTN-139666-07
UILC: 3231.01-00 date: November 02, 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 ceased to be an employer under the
Railroad Retirement Act and the Railroad Unemployment Insurance Act:
---
---
---
---
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 on ------, the date on which it ceased operations and last compensated employees.
According to the RRB opinion, all of its assets and liabilities were transferred to its parent corporation ---.
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Janine Cook cc: