University of Texas System Ex Rel. University of Texas Medical Foundation v. United States

HAYNES, Circuit Judge:

The University of Texas System, on behalf of several of its subsidiary medical institutions (collectively “UT”), sued the United States seeking refund of the Social Security component of Federal Insurance Contributions Act taxes it paid with respect to the service of medical residents in 2005. UT asserted that the residents were exempt from Social Security taxes because they were “students” under an agreement between the State of Texas and the Commissioner of Social Security. After the parties filed cross-motions for summary judgment, the district court denied UT’s…