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education
research
et
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argued
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school
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irs
letter
ruling
may
focusing
hours
individual
works
hours
spends
studies
perfectly
sensible
way
accomplishing
goal
department
explained
individual
service
course
study
separate
distinct
activities
vast
majority
cases
reasoned
mployees
working
enough
hours
considered
employees
filled
conventional
measure
available
time
work
study
fed
reg
department
thus
distinguish
classroom
education
clinical
training
rather
education
service
department
reasonably
concluded
employee
rule
improve
administrability
thereby
avoided
wasteful
litigation
continuing
uncertainty
inevitably
accompany
purely
approach
like
one
mayo
advocates
correll
treasury
department
explained
moreover
employee
rule
recommend
administrative
convenience
department
reasonably
determined
taxing
residents
fica
purpose
social
security
act
comport
precedent
treasury
department
appreciated
understood
terms
social
security
act
breadth
coverage
fed
reg
quoting
social
security
bd
nierotko
instructed
exemptions
taxation
construed
narrowly
bingler
johnson
although
mayo
contends
medical
residents
yet
begun
working
lives
fully
trained
reply
brief
petitioners
internal
quotation
marks
omitted
department
certainly
act
irrationally
concluding
doctors
work
long
hours
serve
highly
skilled
professionals
typically
share
terms
employment
career
employees
kind
workers
congress
intended
contribute
benefit
social
security
system
fed
reg
department
rule
takes
account
ssa
concern
exempting
residents
fica
deprive
residents
families
vital
disability
survivorship
benefits
social
security
provides
mayo
wonders
whether
employee
rule
result
residents
taxed
fica
denied
coverage
ssa
government
informs
us
however
ssa
continues
adhere
longstanding
position
medical
residents
students
thus
remain
eligible
coverage
brief
tr
oral
arg
doubt
mayo
residents
engaged
valuable
educational
pursuit
students
craft
question
whether
students
purposes
however
different
matter
one
congress
directly
spoken
treasury
department
rule
reasonable
construction
congress
said
judgment
appeals
must
affirmed
ordered
justice
kagan
took
part
consideration
decision
case