January 11, 2011
Supreme Court Rules Residents Must Pay Payroll Taxes
The United States Supreme Court released a unanimous decision in Mayo Foundation for Medical Education and Research v. United States, U.S., No. 09-837. This decision found that the Treasury Department was correct in establishing a rule that says medical students are not exempt from paying employment taxes such as Social Security taxes. There is currently a student exception under Section 3121(b)(10) of the Internal Revenue Code, but the Treasury Department rule, which the Supreme Court upheld, found that medical residents who work more than forty hours per week do not quality.
In the ruling the Court states, "We do not doubt that Mayo’s residents are engaged in avaluable educational pursuit or that they are students of their craft. The question whether they are “students” for purposes of §3121, however, is a different matter. Because it is one to which Congress has not directly spoken, and because the Treasury Department’s rule is a reasonable construction of what Congress has said, the judgment of the Court of Appeals must be affirmed."
The Obama administration says that as much as 700 million dollars a year can be collected in Social Security taxes from medical students.
Court observers believe this is the highest profile health care related case brought to the Court this term.