Regan v. United States

MEMORANDUM

YOUNG, District Judge.

I. INTRODUCTION

The Commonwealth of Massachusetts (“the Commonwealth”) has largely abolished county government and transferred county employees to state employ. The United States and the Commonwealth have different perspectives on the impact that this consolidation has on the availability of the continuing-employment exception to the Medicare tax. The issue, as framed below, is one of first impression:

Does the Commonwealth’s abolition of county governments and subsequent transfer of county employees to state employment render the employees newly hired and the…