Employers v. Not Employers

Office of Chief Counsel
Internal Revenue Service
Memorandum
Number: 200814023
Release Date: 4/4/2008
CC:TEGE:EOEG:ET1
POSTN-147968-07
UILC: 3231.01-00 date: December 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 determination that the following business is not a covered 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 the ---is not an employer under the Railroad Retirement Tax Act, since ---, the date it last had an employee conducting rail operations. Please take the appropriate action regarding this business.
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Janine Cook cc: ---