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MAYO FOUND. FOR MED. EDUC. & RES. v. U.S.

No. 09-837.

131 S.Ct. 704 (2011)

562 U.S. 44

MAYO FOUNDATION FOR MEDICAL EDUCATION AND RESEARCH et al., Petitioners, v. UNITED STATES.

Supreme Court of United States.

Decided January 11, 2011.

Attorney(s) appearing for the Case

Theodore B. Olson , Washington, DC, for petitioners.

Matthew D. Roberts , Washington, DC, for respondent.

Justice Kagan recused.

John W. Windhorst, Jr. , Dorsey & Whitney LLP, Minneapolis, MN, Theodore B. Olson , Counsel of Record, Matthew D. McGill , Amir C. Tayrani , Gibson, Dunn & Crutcher LLP, Washington, DC, for Petitioners.

Edwin S. Kneedler , Deputy Solicitor General, Acting Solicitor General, Counsel of Record, John A. DiCicco , Acting Assistant Attorney General, Malcolm L. Stewart , Deputy Solicitor General, Matthew D. Roberts , Assistant to the Solicitor General, Teresa E. McLaughlin , Bridget M. Rowan , Department of Justice, Washington, DC, for U.S.

Chief Justice ROBERTS delivered the opinion of the Court.

Nearly all Americans who work for wages pay taxes on those wages under the Federal Insurance Contributions Act (FICA), which Congress enacted to collect funds for Social Security. The question presented in this case is whether doctors who serve as medical residents are properly viewed as "student[s]" whose service Congress has exempted from FICA taxes under 26 U.S.C. § 3121(b)(10).

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