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On January 11, 2011, the Supreme Court announced its decision in Mayo Foundation for Medical Education and Research v. United States. The question in this case was whether the Treasury Department could categorically exclude medical residents from the definition of "student" in 26 U.S.C. § 3121(b)(10), which exempts from Social Security Taxes "service performed in the employ of a school, college, or university" by a "student who is enrolled and regularly attending classes at such school, college, or university."
Chief Justice Roberts delivered the opinion of the Court, joined by all other Justices except Justice Kagan, who took no part in the consideration or decision of the case. The Court held that the Treasury Department’s rule treating medical residents as full-time employees, and therefore as not exempt from the payment of Social Security Taxes, is a reasonable and binding interpretation of federal law.
To discuss the case, we have Erin M. Hawley, who is an associate at King and Spalding.