United States v. Mayo Foundation for Medical Education and Research

MEMORANDUM OPINION AND ORDER FOR JUDGMENT

KYLE, District Judge.

Introduction

The United States commenced this action to recover approximately $4.1 million paid as a refund to Defendants Mayo Foundation for Medical Education and Research (“MFMER”) and the Mayo Foundation (“the Foundation”) in 1999. That refund represents taxes originally collected from Defendants under the Federal Insurance Contributions Act (“FICA” or “the Act”), 26 U.S.C. §§ 3101 et seq., on stipends paid to residents and fellows of the Mayo Graduate School of Medicine (“MGSM”) in calendar year 1995. 1 Defendants asserted a…