725:
of the employer's classification of the employee, an employee whose normal work schedule is 40 hours or more per week is considered a full-time employee. An employee's normal work schedule is not affected by increases in hours worked caused by work demands unforeseen at the start of an academic term. However, whether an employee is a full-time employee is reevaluated for the remainder of the academic term, if the employee changes employment positions with the employer. An employee's work schedule during academic breaks is not considered in determining whether the employee's normal work schedule is 40 hours or more per week. The determination of an employee's normal work schedule is not affected by the fact that the services performed by the employee may have an educational, instructional, or training aspect." 26
747:
purpose. A regulation may have particular force if it is a substantially contemporaneous construction of the statute by those presumed to have been aware of congressional intent. If the regulation dates from a later period, the manner in which it evolved merits inquiry. Other relevant considerations are the length of time the regulation has been in effect, the reliance placed on it, the consistency of the
Commissioner's interpretation, and the degree of scrutiny Congress has devoted to the regulation during subsequent re-enactments of the statute."
49:
356:, the Court first found that Congress had left the matter to the agency, because the statute was silent on the definition of "student" and on its applicability to medical residents specifically. Second, the Court found, that the regulation was a reasonable interpretation of the statute, and that its clear line helped distinguish workers who study and students who work, simplified enforcement and furthered the broad coverage of Social Security.
626:. In March 2010, while the case was pending before the Supreme Court, the Treasury announced that it would not contest refund claims for taxes paid prior to the April 2005 regulation. It would however assess taxes on salaries paid after that date, which would cost residency programs a total of approximately $ 700 million annually, or $ 3,100 a year for a resident earning $ 50,000 a year (and equivalent amount for the resident's employer).
1731:
448:, the Treasury agreed to repay the taxes it had collected. However, it also promulgated a new regulation to take effect in April 2005, which stated that any full-time employee, including nearly all medical residents, were ineligible to receive the student exemption, clearly stating that it was doing so to "overturn court rulings that had upheld the view that residents remained students".
587:, on the other hand, requires that reviewing courts take into account "whether the regulation harmonizes with the plain language of the statute, its origin, and its purpose" and states that courts may examine a statutory interpretation made years after the passage of the original act on the merits. The Mayo Foundation had requested that the Court rule according to the
583:, a landmark case regarding deference to government agencies, instituted a two-part test: The job of the reviewing court is to first establish whether Congress has unambiguously spoken about the matter. If so, the court is to follow Congress' intent. If not, it is the job of the court to determine whether the agency's statutory interpretation was a reasonable one.
608:, the role of the courts should solely be to determine whether the Treasury Department made a reasonable decision—and the Court concluded that the Treasury did just that. In writing for the Court, Roberts stated that "The department certainly did not act irrationally in concluding that these doctors – 'who work long hours, serve as high [
658:, finding that an agency should have leeway in interpreting the statute in question, no matter when or how long ago the statute was placed in effect, how consistent the agency was in interpreting the statute, the importance of the statute or how closely Congress has looked into the agency's decision. However, an article in the
514:, also argued that the rule was "arbitrary", as the tax would apply to a resident working 40 hours per week but not to a resident working only 39 hours per week. The medical schools proposed that the IRS should base their determination on the primary purpose of a program—providing an education versus providing a livelihood.
418:. An amendment to the Act, passed four years later, provided that a "service performed in the employ of... a school, college, or university... if such service is performed by a student enrolled in and regularly attending classes at such school, college, or university" would be exempt. First-year residents, or
724:
The relevant section of the
Treasury's regulation states: "The services of a full-time employee are not incident to and for the purpose of pursuing a course of study. The determination of whether an employee is a full-time employee is based on the employer's standards and practices, except regardless
499:
from a number of residency programs and medical organizations, argued that a residency is primarily educational in nature. They asserted that a residency is generally chosen based on academic criteria and that a residency must be completed in order for a physician to be licensed to practice medicine.
1392:
In Mayo, the Eighth
Circuit held that the IRS regulation exempting residents was a permissible interpretation of FICA. The Second, Sixth, Seventh, and Eleventh Circuits have come out the other way, finding the IRS regulations contrary to the plain meaning of the "student exception" provision. Those
746:
indicated that the proper standard for judicial review should be the following: "In determining whether a particular regulation carries out the congressional mandate in a proper manner, we look to see whether the regulation harmonizes with the plain language of the statute, its origin, and its
603:
Despite the Mayo
Foundation's arguments otherwise, the Court ruled that "student" was a sufficiently ambiguous term to state that Congress has specifically addressed the issue. The Court also noted that Congress in the past had specifically singled out medical residents when making exemptions
533:
noted that the case was a "very familiar situation of an apprentice who is both an employee and a student," and that the only way that one could draw a line between the two "is to have somebody say: This is going to be the line." He was of the opinion that, if anyone should draw the line, the
380:
exams and complete at least one year of residency training to obtain an unrestricted medical license. In practice, this requires most practicing physicians to complete a multiyear residency first. While training, residents practice medicine with considerable autonomy under the supervision of
645:
as its test for reviewing the
Treasury Department's decision for marked a departure from previous practice; the Court had the courts have previously given less deference to the Internal Revenue Service's statutory interpretations. According to an article in the
550:
appeared to be more favorable to the medical schools, asking the
Justice Department's lawyer at one point "in general, why do medical students become residents? Are they enrolled in the program to make money...or do they want additional education?"
599:
had been superseded. The Court had in fact cited both cases in opinions since 1984, but agreed with the
Government's position, stating that it would not be wise to "carve out an approach to administrative review good for tax law only".
1308:
526:, residents who had not yet obtained their unrestricted medical license, that exemption was removed in 1965 to allow doctors to begin paying into Social Security earlier, so that they could be eligible for certain benefits.
614:] skilled professionals, and typically share some or all of the terms of employment of career employees' – are the kind of workers that Congress intended to both contribute and benefit from the Social Security system".
521:
argued on behalf of the United States that patient care and not educational curricula occupies the vast majority of residents' time. He also argued that although the 1939 FICA Amendment had originally specifically exempted
345:
The
Supreme Court ruled unanimously to uphold the regulation as within the Treasury Department's statutory authority to issue and as a reasonable construction of FICA. The Court clarified that the deferential standard of
633:
noted that "esidents could find additional support in the Court's unambiguous holding for efforts to enforce other workplace rights, such as unemployment benefits (e.g., after hospital closure) or protection under the
792:
Wagner, Derek (2011). "Who's the (Son of) BOSS?: The
Struggle Between the Federal Circuit and Treasury to Define "Omits from Gross Income" in Son of BOSS Tax Shelters and Other Overstatement-of-Basis Tax Cases".
443:
review, and the
University recovered $ 40 million. A number of other residency programs quickly filed lawsuits, attempting to recoup the taxes they had paid. After some of those programs were successful in other
1814:
1558:
575:
542:, on the other hand, felt that residents were employees, as evidenced by her statement "You don't think receiving $ 50,000 or $ 60,000 a year is enough to make you an employee of someone?" According to
348:
136:
1735:
180:
are categorically ineligible for the student exemption from Social Security taxes codified at 26 U.S.C. §3121(b)(10), is a reasonable construction of that statute. Eighth Circuit affirmed.
1304:
28:
485:
481:
898:
1746:
473:
465:
434:
155:
100:
1507:
1794:
477:
392:
391:. Residents in the past had literally resided in hospitals for the duration of their training. By 2010, when the case was argued before the Supreme Court, regulations from the
681:
test is only to be used in "complex questions of statutory interpretation" and that the Court left open the possibility that a future scenario may warrant the use of the
1804:
433:
sued to recover a small portion of those taxes. An initial administrative review ruled for the Social Security Administration, but the district court reversed. The
425:
Until the 1990s, the Act and its application to medical residents were not an issue. Many hospitals assessed and paid FICA taxes on behalf of their employees. The
315:
regulation on the grounds that the courts should defer to government agencies in tax cases in absence of an unreasonable decision on the part of the agency.
326:
taxes. The Treasury Department issued a regulation in 2004, declaring those who worked more than 40 hours a week were ineligible for such an exemption. The
1109:
1647:
Orenbach, Kenneth B. (2011). "A New Twist to an On-Going Debate About Securities Self-Regulation: It's Time to End FINRA's Federal Income Tax Exemption".
805:
Berg, Michael E. (2008). "Judicial Deference to Tax Regulations: A Reconsideration in Light of National Cable, Swallows Holding, and Other Developments".
1789:
364:
In the first decade of the 21st century the vast majority of medical residents in the United States were physicians, who had recently graduated from a
1113:
622:
The Mayo Clinic noted that it had been paying the taxes while the case was pending in the courts, so the 15-page opinion would not force them to pay
500:
They also argued that residency training involves not only supervised work, but also an educational curriculum, conferences, and lectures, much like
1077:
1530:
488:
Circuits, which had all previously ruled that residents may count as students for the purpose of FICA taxes. The Eighth Circuit's ruling created a
1784:
1393:
circuits held that a case-by-case approach is required to determine whether residents serving at specific institutions qualify for the exception.
342:
by the medical profession. The District Court ruled for the Mayo Foundation and struck the regulation, but was reversed by the Court of Appeals.
1020:
564:
508:
995:
882:
569:
501:
407:
365:
319:
287:
1499:
834:
559:
In a decision written by Chief Justice Roberts, the Supreme Court unanimously upheld the Eighth Circuit's decision. Associate Justice
53:
1687:
1414:
McMahon, Martin J. Jr.; Shepard, Ira B.; Simmons, Daniel L. (2011). "Recent Developments in Federal Income Taxation: The Year 2010".
749:
McMahon, Martin J. Jr.; Shepard, Ira B.; Simmons, Daniel L. (2011). "Recent Developments in Federal Income Taxation: The Year 2010".
1799:
312:
1659:
Aprill, Ellen P.; Galler, Linda; Salem, Irving (2004). "ABA Section on Taxation, Report of the Task Force on Judicial Deference".
604:
available, which in the Court's eyes made the Mayo Foundation's arguments about unambiguity unreasonable. Therefore, according to
396:
1359:
La Fleur, Zachary (2010). "Are Medical Residents Classified as Full-Time or Student Employees Under FICA and IRS Regulations?".
1267:
445:
415:
323:
838:
708:
test does not depend on whether Congress intended to delegate out general authority over a matter or just specific authority.
430:
422:, were also specifically exempted. In 1965, Congress repealed the intern exemption but left the student exemption in place.
352:(1984) applied, notwithstanding prior Court rulings that had adopted a more stringent standard to tax regulations. Applying
72:
Mayo Foundation for Medical Education and Research; Mayo Clinic; and Regents of the University of Minnesota v. United States
700:
505:
874:
461:
457:
1439:
1139:
729:
726:
388:
308:
294:
291:
173:
1379:
1165:
Cohen, Wilbur J. (1983). "The Development of the Social Security Act of 1935: Reflections Some Fifty Years Later".
472:
the cases for entry of judgments in favor of the United States. This decision was at odds with decisions from the
694:
1117:
635:
535:
469:
563:
recused herself from participating in the case, as she had signed the government's brief during her tenure as
1042:
Levin, R. (1988). "Beyond "The Men of Steel": The Origins and Significance of House Staff Training Stress".
426:
142:
1596:
1473:
1330:
1277:
1084:
1750:
776:
667:
523:
419:
279:
92:
1305:"Supreme Court Upholds IRS Regulation Saying Medical Residents are "Students" and Subject to FICA Tax"
1809:
1622:
1253:
331:
1078:"Resident Duty Hours in the Learning and Working Environment: Comparison of 2003 and 2011 Standards"
1012:
1197:
Kesselheim, A. S.; Austad, K. E. (2011). "Residents: Workers or Students in the Eyes of the Law?".
382:
223:
27:
This article is about a case involving Social Security taxes. For the service of process case, see
518:
1440:"Supreme Court says medical residents are considered employees for Social Security tax purposes"
1232:
Lerner, Justin (2010–2011). "Comment: United States v. Memorial Sloan-Kettering Cancer Center".
17:
368:. While graduating from a medical school provides an individual with a medical degree, a state
1668:
1214:
1059:
991:
942:
878:
339:
132:
1672:
961:
921:"Commentary: Watching Closely at a Distance: Key Tensions in Supervising Resident Physicians"
1535:
1206:
1051:
932:
372:
is required to practice medicine. All states require, that an individual pass Step 3 of the
1702:
539:
369:
327:
283:
239:
215:
211:
330:
filed suit to challenge the regulation and for a refund of the taxes it had paid on its
511:
439:
227:
203:
1757:
81:
1778:
1281:
1055:
779:
670:
489:
335:
177:
399:
had limited work hours to about 80 hours per week, and a first-year resident at the
1623:"Medical Schools Must Pay Social Security Taxes for Residents, Supreme Court Rules"
1272:
547:
530:
496:
235:
195:
151:
1447:
845:
937:
920:
176:§31.3121(b)(10)– 2(d)(3)(iii), providing that student employees working at least
95:
560:
411:
400:
247:
129:
650:, the Court in doing so "unambiguously overruled" its previous decision in the
1730:
1334:
623:
264:
Roberts, joined by Scalia, Kennedy, Thomas, Ginsburg, Breyer, Alito, Sotomayor
159:
1083:. Accreditation Council for Graduate Medical Education. 2010. Archived from
107:
1218:
946:
42:
Mayo Foundation for Medical Education and Research, et al. v. United States
1143:
1142:. Mayo School of Graduate Medical Education. July 21, 2010. Archived from
1063:
677:
may not have been entirely overruled, arguing that the Court implied that
322:(FICA), students and their educational employers are exempted from paying
1766:
1210:
990:(1 ed.). New York City: Grand Central Publishing. pp. 200–201.
389:
Medical residencies traditionally require lengthy hours of their trainees
1688:"Judicial Deference to Retroactive Interpretative Treasury Regulations"
591:
standard, while the United States argued that the Court should use the
1380:"Supreme Court to hear several cases affecting labor & employment"
1743:
Mayo Foundation for Medical Education & Research v. United States
414:
on workers. The revenues of the tax were meant to be used to finance
377:
126:
Mayo Foundation for Medical Education and Research v. United States
373:
468:
consolidated the two cases into one and reversed the judgments,
269:
Kagan took no part in the consideration or decision of the case.
148:
1559:
Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc.
576:
Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc.
349:
Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc.
48:
1016:
610:
452:
Lower court proceedings and arguments before the Supreme Court
1736:
Mayo Foundation for Medical Ed. and Research v. United States
1579:
Mayo Foundation for Medical Ed. and Research v. United States
492:, and on appeal, the Supreme Court agreed to hear the case.
429:'s hospitals did not, however, and in the early 1990s, the
1582:, 562 U.S. ___, Part II (S. Ct. 2011).
1563:, 467 U.S. 837, 842–843 (S. Ct. 1984).
1013:"Today's medical training – better or worse for patients?"
1474:"Justices Reluctant to Let Medical Residents Skip Taxes"
1268:"High court rules medical residents must pay FICA taxes"
456:
The Mayo Clinic and the University of Minnesota sued in
437:
affirmed the district court's decision after granting a
29:
United States ex rel. Gerald Mayo v. Satan and His Staff
1815:
United States Supreme Court cases of the Roberts Court
1354:
1352:
573:(1979), the Court instead used a standard set out in
570:
National Muffler Dealers Assn., Inc. v. United States
147:, 2008 WL 906799 (D. Minn. 2008); both reversed, 568
1595:
Kendall, Brent; Vaughan, Martin (January 11, 2011).
393:
Accreditation Council for Graduate Medical Education
338:
providing patient care but who are still considered
871:
State Medical Licensure Requirements and Statistics
666:
standard in reviewing retroactive tax regulations (
334:—recently graduated physicians, who work more than
273:
260:
255:
184:
166:
120:
115:
87:
77:
67:
60:
41:
567:. Declining to review using a standard set out in
1500:"Court seems divided on taxing medical residents"
786:"created confusion among the lower courts". The
517:In response, Assistant to the Solicitor General
1573:
1571:
1569:
775:standard to "tax regulations promulgated under
406:In 1935, the United States Congress passed the
1409:
1407:
1405:
1403:
1401:
839:"Results and Data: 2010 Main Residency Match"
8:
962:"More Physicians Say No to Endless Workdays"
1795:United States taxation and revenue case law
1597:"Tax on Medical Residents Upheld by Court"
1378:Winston & Strawn LLP (July 19, 2010).
38:
1114:Lake Erie College of Osteopathic Medicine
936:
739:
737:
172:The Treasury Department's regulation, 26
1192:
1190:
1188:
1186:
1184:
1182:
1180:
1590:
1588:
1467:
1465:
1331:"Court: Medical residents not students"
1011:Gajilan, A. Chris (September 6, 2006).
844:(2 ed.). p. 9. Archived from
826:
717:
464:agreed with them, but upon appeal, the
1805:Medical education in the United States
1498:Holland, Jesse J. (November 8, 2010).
1438:Holland, Jesse J. (January 11, 2011).
1307:. Council on Law in Higher Education.
1303:Harding, Bertrand (January 24, 2011).
565:Solicitor General of the United States
1433:
1431:
1429:
1311:from the original on October 30, 2011
701:United States v. Vogel Fertilizer Co.
538:should be the one. Associate Justice
529:During oral arguments, Chief Justice
36:2011 United States Supreme Court case
7:
1621:Kelderman, Eric (January 11, 2011).
1529:Stripling, Jack (January 12, 2011).
1472:Vaughan, Martin (November 8, 2010).
641:The Supreme Court's decision to use
1531:"Medical Residents Ruled Employees"
662:which advocates for the use of the
460:to overturn those regulations. The
408:Federal Insurance Contributions Act
366:medical school in the United States
320:Federal Insurance Contributions Act
288:Federal Insurance Contributions Act
1510:from the original on June 28, 2011
1446:. Associated Press. Archived from
1361:American Journal of Trial Advocacy
1266:Phelps, David (January 12, 2011).
1023:from the original on June 24, 2010
960:Harris, Gardiner (April 1, 2011).
835:National Resident Matching Program
54:Supreme Court of the United States
25:
1790:United States Supreme Court cases
1627:The Chronicle of Higher Education
771:, the Court's application of the
495:Mayo and Minnesota, supported by
311:case in which the Court upheld a
1753:44 (2011) is available from:
1729:
1110:"Intern & Resident Policies"
901:Mayo Foundation v. United States
502:clinical years of medical school
397:American Osteopathic Association
304:Mayo Foundation v. United States
47:
18:Mayo Foundation v. United States
1199:New England Journal of Medicine
795:The Federal Circuit Bar Journal
769:The Federal Circuit Bar Journal
631:New England Journal of Medicine
162:. granted, 560 U.S. ___ (2010).
1785:2011 in United States case law
1234:New York Law School Law Review
431:Social Security Administration
1:
1140:"Compensation & Benefits"
790:decision settled the matter.
730:§31.3121(b)(10)– 2(d)(3)(iii)
403:made $ 47,259 plus benefits.
295:§31.3121(b)(10)– 2(d)(3)(iii)
1695:George Washington Law Review
1056:10.1016/0163-8343(88)90096-5
938:10.1097/ACM.0b013e3181eb4fa4
875:American Medical Association
660:George Washington Law Review
1044:General Hospital Psychiatry
767:According to an article in
695:Rowan Cos. v. United States
309:United States Supreme Court
307:, 562 U.S. 44 (2011), is a
1831:
1767:Oyez (oral argument audio)
899:"Brief for Petitioners in
504:. Mayo's attorney, former
26:
782:" in the years following
704:(1982), stating that the
692:The Court also overruled
278:
268:
189:
171:
124:Judgment for plaintiffs,
46:
1800:Social Security lawsuits
636:Family Medical Leave Act
536:Internal Revenue Service
410:(FICA), which imposed a
63:Decided January 11, 2011
1686:Pruitt, Andrew (2011).
595:standard, arguing that
544:The Wall Street Journal
427:University of Minnesota
143:University of Minnesota
61:Argued November 8, 2010
1701:: 1558. Archived from
1278:Minneapolis, Minnesota
1116:. 2010. Archived from
988:This Won't Hurt a Bit
986:Au, Michelle (2011).
1506:. Associated Press.
1211:10.1056/NEJMp1100414
1167:Minnesota Law Review
1146:on February 25, 2011
1120:on February 17, 2011
919:Babbott, S. (2010).
851:on December 27, 2010
685:test instead of the
555:Opinion of the Court
546:, Associate Justice
383:attending physicians
106:131 S. Ct. 704; 178
1708:on December 1, 2011
1649:Virginia Tax Review
1601:Wall Street Journal
1478:Wall Street Journal
1450:on January 28, 2011
1284:on October 14, 2012
1251:Minnesota v. Apfel,
803:, partially citing
506:Bush Administration
313:Treasury Department
284:§ §3121(b)(10)
224:Ruth Bader Ginsburg
1416:Florida Tax Review
1337:. January 11, 2011
751:Florida Tax Review
648:Florida Tax Review
629:An article in the
519:Matthew D. Roberts
200:Associate Justices
110:588; 2011 WL 66433
1734:Works related to
997:978-0-446-53824-4
925:Academic Medicine
884:978-1-60359-108-9
509:Solicitor General
332:medical residents
300:
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16:(Redirected from
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1280:. Archived from
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931:(9): 1399–1400.
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773:National Muffler
765:
759:
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744:National Muffler
741:
732:
722:
683:National Muffler
675:National Muffler
664:National Muffler
652:National Muffler
597:National Muffler
589:National Muffler
585:National Muffler
185:Court membership
145:v. United States
51:
50:
39:
21:
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1324:
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1265:
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1260:
1256:(8th Cir. 1998)
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1245:
1231:
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1226:
1196:
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1149:
1147:
1138:
1137:
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1123:
1121:
1108:
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1103:
1093:
1091:
1090:on May 31, 2011
1087:
1080:
1076:
1075:
1071:
1041:
1040:
1036:
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