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MAYO FOUNDATION FOR MEDICAL EDUCATION v. U.S.

Civ. No. 06-5059 (RHK/JSM).

503 F.Supp.2d 1164 (2007)

MAYO FOUNDATION FOR MEDICAL EDUCATION AND RESEARCH and Mayo Clinic, Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, D. Minnesota.

August 3, 2007.

Attorney(s) appearing for the Case

Thomas W. Tinkham, John W. Windhorst, Jr., Christopher R. Duggan, Kristina W. Carlson, Emily L. Fitzgerald, Dorsey & Whitney LLP, Minneapolis, MN, Robert M. Moore, Jr., Joanne L. Martin, Mayo Clinic, Rochester, MN, for Plaintiffs.

Michael R. Pahl, Trial Attorney, Tax Division, United States Department of Justice, Washington, D.C., for Defendant.

MEMORANDUM OPINION AND ORDER

KYLE, District Judge.

INTRODUCTION

Plaintiffs Mayo Foundation for Medical Education and Research ("MFMER") and Mayo Clinic ("Mayo") commenced this action against Defendant United States of America for the refund of FICA taxes withheld and paid on Mayo's medical residents' stipends during the second quarter of 2005. The amount of Mayo's claim is $1,676,118.06, plus interest...

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