United States v. Mount Sinai Medical Center of Florida, Inc., No. 02-22715-CIV-GOLD, 2008 U.S. Dist. LEXIS 57808 (S.D. Fla. Jul. 28, 2008)

(plaintiff must refund $2.5 million in FICA taxes paid by defendant on its residents' stipends; residents are excepted from FICA taxation under I.R.C. §3121(b)(10) because the facility qualified as a school, college or university and the residents were students).