Legal Opinion

Mayo Foundation for Medical Education & Research v. United States

District Court, D. Minnesota

Decided August 3, 2007No. Civ. 06-5059 (RHK/JSM)PublishedCited by 6 opinions

1Opinion of the Court

MEMORANDUM OPINION AND ORDER

KYLE, District Judge.

INTRODUCTION

Plaintiffs Mayo Foundation for Medical Education and Research (“MFMER”) and Mayo Clinic (“Mayo”) commenced this action against Defendant United States of America for the refund of FICA taxes withheld and paid on Mayo’s medical residents’ stipends during the second quarter of 2005. The amount of Mayo’s claim is $1,676,118.06, plus interest. This Court held in 2008 that stipends paid to medical residents in 1994-1996 qualify for the “student” exclusion from FICA taxation and that Mayo is a “school, college, or university” for purposes…

2Cases cited28 opinions

  1. Anderson v. Liberty Lobby, Inc.Supreme Court of the United States · 1986
  2. Celotex Corp. v. Catrett, Administratrix of the Estate of CatrettSupreme Court of the United States · 1986
  3. Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
  4. Consumer Product Safety Commission v. GTE Sylvania, Inc.Supreme Court of the United States · 1980
  5. National Cable & Telecommunications Assn. v. Brand X Internet ServicesSupreme Court of the United States · 2005

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3Cited by6 opinions

  1. Mayo Foundation for Medical Education & Research v. United StatesCourt of Appeals for the Eighth Circuit · 2009
  2. Mayo Foundation for Medical Education & Research v. United StatesSupreme Court of the United States · 2011
  3. Mayo Foundation for Medical Education & Research v. United StatesSupreme Court of the United States · 2011
  4. Intermountain Insurance Service of Vail, Ltd. Liability Co. v. CommissionerUnited States Tax Court · 2010
  5. Intermountain Insurance Service of Vail, Ltd. Liability Co. v. CommissionerUnited States Tax Court · 2010

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