Medical Residents FICA Litigation: Supreme Court Hears Challenge to IRS Regulations


The Supreme Court heard oral argument in Mayo Foundation for Medical Education and Research v. United States, No. 09-837.

At issue is the validity of an IRS regulation that makes medical residents categorically ineligible for the so-called “student exception” to FICA taxes. The regulation was enacted by the IRS after years of litigation regarding whether medical residents – and the academic medical centers that train them – are exempt from paying FICA taxes on medical resident stipends. Mayo prevailed on its initial challenge to the regulations in federal court in Minnesota, but the 8th Circuit reversed, upholding the regulations? validity.

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