Nothing can be said to be certain, except death and taxes, especially taxes.

Last week the United States Supreme Court provided its opinion on case No. 09-837 Mayo Foundation for Medical Education and Research, Et al., Petitioners v. United States. The University of Minnesota Regents joined the petitioners that asked the question of the court: “Are medical residents students or employees?”

The unanimous opinion affirmed the Treasury Department’s rule that treats medical residents as full-time employees and subjects them to the Federal Insurance Contributions Act, or FICA tax.

The opinion is more than just a disappointment to the University; it’s the end of an era. Since 1951 when the Treasury Department applied its regulations defining the 1939 student exception to FICA, the University of Minnesota’s Medical School has tried to determine the status and eligibility of exemptions for medical residents, interns, and fellows.

View selected correspondence from deans Harold Diehl and Robert Howard discussing the Internal Revenue Service and Treasury Department’s positions and the process for classifying hospital interns, residents, and fellows in the 1950s.