In a unanimous decision, the Supreme Court has upheld a Treasury regulation requiring medical residents to pay FICA tax. This tax, used to fund Social Security benefits, provides an exemption for amounts received by students for work that is incidental to their studies. The regulation says this exemption does not apply to the services of a full-time employee normally scheduled to work 40 hours or more per week. Medical residents typically spend more than 40 hours per week treating patients. A District Court ruling held the regulation invalid but was reversed on appeal, and the Supreme Court has put the issue to rest: full-time work does not qualify for the student exemption.

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