Employers v. Not Employers

Office of Chief Counsel
Internal Revenue Service
Memorandum
Number: 200822025
Release Date: 5/30/2008
CC:TEGE:EOEG:ET1
POSTN-155896-07
UILC: 3231.01-00 date: February 26, 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 following business ceased to be a covered employer under the Railroad Retirement Act and the Railroad Unemployment Insurance Act as of ---:
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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 ------ceased to a covered employer under the Railroad Retirement Tax Act no later than ---, because the company lost its status as a legal entity as a result of corporate merger. While the RRB opinion does not address the matter, we believe the entity into which --- merged was already an employer under the Railroad Retirement Act.
POSTN-155896-07 2
Please take the appropriate action regarding this business.
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Janine Cook
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