Center for Family Medicine et al. v. United States, No. 05-4049-KES, 2008 U.S. Dist. LEXIS 59816 (D. S.D. Aug. 6, 2008)

(two medical facilities entitled to a refund of FICA taxes paid on medical residents' stipends because they qualify for the student exclusion from FICA taxation but not on taxes paid for head residents who elected to stay after completing their residency programs to help administer the program).