Ltv Steel Company, Inc. v. United States

BRYSON, Circuit Judge.

The government appeals the ruling of the Court of Federal Claims that pension payments made to certain former employees of the taxpayer’s predecessor companies were exempt from tax liability under the Federal Insurance Contributions Act (FICA) and the Federal Unemployment Tax Act (FUTA). We conclude that the payments in question did not qualify for exemption, and we therefore reverse.

I

Plaintiff LTV Steel Company, Inc., (LTV Steel) is a subsidiary of LTV Corporation. LTV Steel was formed in 1984 from two other LTV Corporation subsidiaries, Republic Steel Corporation and…