Employers v. Not Employers

Office of Chief Counsel
Internal Revenue Service
Memorandum
Number: 200821033
Release Date: 5/23/2008
CC:TEGE:EOEG:ET1
POSTN-155487-07
UILC: 3231.01-00 date: February 12, 2008 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 status of the following business as a covered employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act ended on ---:
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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 status of the------ as an employer under the Railroad Retirement Tax Act ended on ------, the last day of the period during which it lost its status as a legal entity and became non-existent as a result of corporate merger.
Please take the appropriate action regarding this business.
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Janine Cook cc: