ABSTRACT
In Mayo Foundation v. U.S., the United States Supreme Court recently ended a dispute as to whether stipends paid to medical residents are subject to FICA. A statutory provision excludes “students” from FICA, and the question was whether medical residents could be considered students, thereby making them eligible for the exclusion. The Treasury Department amended its definition of “student,” as that term is used in the Internal Revenue Code (IRC), following adverse decisions in several circuits. What began as a case of statutory construction turned into one of administrative authority. Ultimately, the Court upheld the regulation, which categorically denies medical residents from being eligible for the student exemption. The Supreme Court's decision reaches far beyond this narrow issue, however, because the underlying analysis applies in all areas of administrative law. The Court made clear that a uniform standard of deference applies not only to the Treasury Department, but to all administrative agencies. That standard, which was announced by the Court in Chevron USA v. Natural Resources Defense Council, Inc. in 1984, states that an agency's rule or interpretation will be upheld as long as Congress was silent or ambiguous with regard to the issue at hand, and the rule or interpretation is a permissible construction of the statute.