FICA Taxes on Medical Residents

Govt. was denied summary judgment on univ. hospital's student exclusion-based complaint for refund of FICA taxes paid on behalf of medical residents: taxpayer was entitled to particularized review of whether its residents came under exclusion based on plain language of Reg. § 31.3121(b)(10)-2(b) and provision that amount of remuneration students received for services performed was immaterial to exclusion determination, contrary to govt.'s nominal amount only exclusion interpretation. (The University Of Chicago Hospitals v. U.S., DC, Northern Dist. of IL, 98 AFTR 2d ¶2006-5525 )

Have questions? I’m here to help.