LTV Steel Co., Inc. v. United States, 215 F.3d 1275 (Fed Cir. 2000)-In this case, LTV Steel contested the application of FICA and FUTA taxes to payments it made under nonqualified plans. The company hoped to fall under a 1983 transitional rule which continued exempt status for agreements already in existence in March of that year. LTV argued that certain 1987 agreements continued to fall under that coverage since they "referred to" or were made "in the case of" the pre-1983 agreements insofar as they satisfied lingering obligations from the earlier agreements.

This court reversed the judgment in favor of  LTV, pointing out that the trial court misapplied the "origin of the claim doctrine." That doctrine only applies to cases in which the tax status of a settlement or award of damages is unclear. Here, the 1987 tax laws clearly cover the 1987 agreements.  The earlier agreements had been terminated, and were no longer paying benefits to any beneficiaries. A payment that is specifically made subject to taxation is not rendered exempt from tax simply because it is made in settlement of an obligation which, had it been paid, would not have been taxed.