United States v. Memorial Sloan-Kettering Cancer Center

HALL, Circuit Judge:

These two cases, Albany Medical Center v. United States (“AMC”), No. 1:04-CV-1399, 2007 WL 119415 (N.D.N.Y. Jan. 10, 1997) (Scullin, J.) and United States v. Memorial Sloarir-Kettering Cancer Center (“Sloan-Kettering”) (Hellerstein, /.), decided respectively by the United States District Courts for the Northern and Southern Districts of New York, both raise the question of whether post-graduate medical residents can invoke the Federal Insurance Contributions Act (“FICA”) tax exemption for “students.” In each case, the district court ruled that, as a matter of law,…