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''Mayo Foundation v. United States'', 562 U.S. 44 (2011), is a United States Supreme Court case in which the Court upheld a Treasury Department 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. Under the Federal Insurance Contributions Act (FICA), students and their educational employers are exempted from paying Social Security 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 Mayo Foundation filed suit to challenge the regulation and for a refund of the taxes it had paid on its medical residents—recently graduated physicians who work more than full-time providing patient care, but who often have only a limited license to practice medicine and are still considered students by the medical profession. The District Court ruled for the Mayo Foundation and struck the regulation, but was reversed by the Court of Appeals. 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 ''Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc.'' (1984) applied, notwithstanding prior Court rulings that had adopted a more stringent standard to tax regulations. Applying ''Chevron'', the Court first found that Congress had left the matter to the agency because the statute was silent on the definition of "student" and 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. ==Background== 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 medical school in the United States. While graduating from a medical school provides an individual with a medical degree, a state medical license is required to practice medicine. All states require that an individual pass Step 3 of the USMLE or COMLEX exams and complete at least one year of residency training to obtain an unrestricted medical license; in practice, most practicing physicians complete their multiyear residency.〔(【引用サイトリンク】title=Brief for Petitioners in ''Mayo Foundation v. United States'' )〕 While training, residents practice medicine with considerable autonomy under the supervision of attending physicians. Medical residencies traditionally require lengthy hours of their trainees. 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 Accreditation Council for Graduate Medical Education and the American Osteopathic Association had limited work hours to about 80 hours per week, and a first-year resident at the Mayo Clinic made $47,259 plus benefits. In 1935, the United States Congress passed the Federal Insurance Contributions Act (FICA), which imposed a payroll tax on workers. The revenues of the tax were meant to be used to finance Social Security. 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 interns, were also specifically exempted. In 1965, Congress repealed the intern exemption but left the student exemption in place. 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 University of Minnesota's hospitals did not, however, and in the early 1990s, the Social Security Administration 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 Eighth Circuit affirmed the district court's decision after granting a ''de novo'' review,〔''Minnesota v. Apfel,'' (151 F.3d 742 ) (8th Cir. 1998)〕 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 circuit courts, the Treasury agreed to repay the taxes it had collected. However, it also promulgated a new regulation to take effect in April 2005 that stated that any full-time employee, which includes nearly all medical residents, were ineligible to receive the student exemption,〔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 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 C.F.R (§31.3121(b)(10)– 2(d)(3)(iii) )〕〔 clearly stating that it was doing so to "overturn court rulings that had upheld the view that residents remained students". 抄文引用元・出典: フリー百科事典『 ウィキペディア（Wikipedia）』 ■ウィキペディアで「Mayo Foundation for Medical Education & Research v. United States」の詳細全文を読む スポンサード リンク
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