http://www.utsouthwestern.edu/educa...ynecology/education-training/fellowships.html
"American Board of Obstetrics and Gynecology (ABOG) fellows are considered trainees, and their appointment to ABOG-fellowship programs are for purposes of training. There is no employer-employee relationship. In spite of the fact that stipends are considered taxable income to the recipient, the IRS has ruled that UT Southwestern may not withhold income taxes from non-employee, trainee stipends. Fellows are urged to read IRS publication 970, Tax Benefits for Education, and to contact a tax advisor."
I thought there was a court case out there that the IRS was fighting that said residents/fellows are NOT trainees and their taxes must be withheld (I think Mayo was one of the main places that was fighting for trainee not employee status). I thought the IRS had won that case as well but I'm not sure.