Is the IRS' Chief Counsel Advice Memorandum on student status for the resident FICA reimbursement

http://www.irs.gov/pub/irs-wd/0212029.pdf

the final word in this matter? Is the issue completely settled, or is there still a chance to get the reimbursement? I was a resident from 1999 to 2002, so this is the last year to file for 1999.



All the info on the web is outdated and inconclusive, namely some people have been granted the refund, others have been denied, others may have been asked to return the refund they did receive (supposedly with penalty), and I have yet to find a single outcome of the class-action lawsuits that have been filed.



Has anyone outside of the university of minnesota class-action suit gotten a refund? If so, there must be some criteria that the IRS uses. How do I determine if I/my-residency-program qualify? I have called numerous offices at my residency program, and no one knows anything about the reimbursement; likewise I can't find anyone at the program in a position to say that the program will NOT be filing a class-action suit.



The bottom line: Should I apply for the reimbursement, or does the above memorandum guarantee failure?



Thanks in advance!

Zip Code: surferboy690@hotmail.com