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The U.S. Supreme Court opens its 2010 term today with three tax cases on its docket, including a review of the Eighth Circuit's finding that regulations issued by IRS regarding the taxation of medical residents were a reasonable interpretation of the student exception under FICA. The Eighth Circuit's ruling created a circuit split when the court said that, while the act excludes “wages” paid to a student from its coverage, the regulations reasonably clarified that “wages” paid to a full-time employee by a college or university are not excluded. Four other circuits have come to the opposite conclusion.
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