Supreme Court of the United States
Mayo Foundation for Medical Education and Research v. United States
January 11, 2011562 U.S. 44
Summary
The Supreme Court unanimously held that Chevron deference applies to Treasury Department regulations interpreting the Internal Revenue Code, replacing the previously applied National Muffler test. The Court affirmed the Eighth Circuit, ruling that the Treasury’s full-time employee rule, which categorically excludes medical residents from the FICA student exemption, is a reasonable interpretation of an ambiguous statute.
Holding
- Standard of review for Treasury Department regulations interpreting the Internal Revenue Code.. Chevron deference applies to Treasury regulations under 26 U.S.C. § 7805(a), superseding the more deferential National Muffler test and distinctions between general and specific delegations of authority.
- Validity of the full-time employee rule under the student exception.. The Treasury’s full-time employee rule is a reasonable interpretation of the student exemption under 26 U.S.C. § 3121(b)(10).
Docket No. 09-837
Cited authorities
- Rev. Rul. 78-17
- 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