Mayo Foundation for Medical Education & Research v. United States
Court of Appeals for the Eighth Circuit
1Opinion of the Court
LOKEN, Chief Judge.
“Residents” participating in accredited graduate medical education programs receive substantial payments (called stipends) from the Mayo Foundation for Medical Education and Research (“Mayo”) and the University of Minnesota (the “University”) for medical and patient care services provided by the residents at affiliated and unaffiliated hospitals and clinics. The difficult issue in these cases is whether these payments qualify for the student exception to Federal Insurance Contributions Act (“FICA”) taxes imposed on employers and employees. See 26 U.S.C. § 3121(b)(10). The…
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