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Tax Lawyer, Vol. 63, No. 2 NOTE 603603NOTETenure Trap: Third Circuit Joins Sixth in Holding Tenure Buy-out Payments Subject to FICA Taxation in University of Pittsburgh v. United StatesI. IntroductionIn University of Pittsburgh v. United States, the Third Circuit held that early retirement payments to professors, which required the relinquishment of tenuur rights, qualified as wages subject to Federal Insurance Contributions Act (FICA) taxation.1 The University of Pittsburgh (the University)...