Supreme Court of the United States
Mayo Foundation for Medical Education and Research v. United States
January 11, 2011131 S. Ct. 704
Summary
The Supreme Court affirmed the Eighth Circuit, holding that the Treasury Department's full‑time employee rule is a permissible construction of the student exemption in §3121(b)(10) and therefore medical residents are not exempt from FICA taxes.
Holding
- Whether doctors serving as medical residents qualify as “students” exempt from FICA taxes under 26 U.S.C. §3121(b)(10).. Medical residents are not “students” within the meaning of §3121(b)(10) and therefore are not exempt from FICA taxes.
- Whether the Treasury Department’s full‑time employee regulation is entitled to Chevron deference.. The regulation is entitled to Chevron deference and is a permissible construction of the statute.
Docket 09-837
Cited authorities
- 47 U.S.C. § 201(b)
- IRS Letter Ruling 9332005
- 26 U.S.C. § 3121
- 26 U.S.C. § 3101
- 42 U.S.C. § 410
- 16 FR 12474
- Treas. Reg. § 31.3121
- 26 C.F.R. §31.3121
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