One of your clients is Professor Bart Simpson, a former tenured professor at Big State University. A couple years ago, he accepted an early retirement package from BSU. Under the agreement, he received a lump-sum payment equal to two years salary in exchange for his retirement and the release of all rights associated with his tenure. In executing the agreement, BSU did not withhold any FICA tax from the lump-sum payment. On audit, the IRS contends that this lump-sum payment is properly characterized as wage income. As such, it is seeking amounts that would have been withheld under FICA, as well as associated penalties and interest. Professor Simpson has engaged you to assist him with this matter. Is the IRS correct, or did Professor Simpson and BSU properly refuse to subject the lump-sum payment to FICA? paragraph or two