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U.S. v. MAYO FOUNDATION FOR MEDICAL EDUCATION AND RESEARCH

No. Civ.01-1121 RHK/SRN.

282 F.Supp.2d 997 (2003)

UNITED STATES of America, Plaintiff, v. MAYO FOUNDATION FOR MEDICAL EDUCATION AND RESEARCH, and Mayo Foundation, Defendants.

United States District Court, D. Minnesota.

August 4, 2003.

Attorney(s) appearing for the Case

Gerald Leedom and Jennifer Brown, United States Department of Justice, Tax Division, Washington, D.C., for Plaintiff.

Thomas W. Tinkham and John Windhorst, Dorsey & Whitney, P.L.L.P., Minneapolis, Minnesota, for Defendants.

MEMORANDUM OPINION AND ORDER FOR JUDGMENT

KYLE, District Judge.

Introduction

The United States commenced this action to recover approximately $4.1 million paid as a refund to Defendants Mayo Foundation for Medical Education and Research ("MFMER") and the Mayo Foundation ("the Foundation") in 1999. That refund represents taxes originally collected from Defendants under the Federal Insurance Contributions Act ("FICA" or "the Act"), 26 U.S.C. §...

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