Budhwani v. Commissioner
United States Tax Court
Petitioner, a citizen of Pakistan, entered the United States in 1973 under an F-1 visa as a nonimmigrant student. He was enrolled in college courses during 1973 and 1974, and was also employed full time during these years beginning in June 1973. Petitioner paid no income tax to Pakistan on the salary earned in the United States.
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Petitioner, a citizen of Pakistan, entered the United States in 1973 under an F-1 visa as a nonimmigrant student. He was enrolled in college courses during 1973 and 1974, and was also employed full time during these years beginning in June 1973. Petitioner paid no income tax to Pakistan on the salary earned in the United States. Held, petitioner is not entitled to exclude from U.S. taxation $ 5,000 of income earned in the United States during 1974 under the income tax treaty between the United States and Pakistan because (1) petitioner was not a resident of Pakistan for treaty purposes, and…
1Opinion of the Court
Wilbur, Judge:
Respondent determined a deficiency of $1,524.06 in petitioner’s Federal income tax for the calendar year 1974. The sole issue for decision is whether $5,000 of income earned by petitioner in the United States during 1974 is exempt from United States tax under the provisions of the income tax treaty between the United States and Pakistan.
FINDINGS OF FACT
Some of the facts have been stipulated and are found accordingly.
Petitioner maintained his legal residence in Glendale Heights, Ill., at the time he filed the petition in this case. He timely filed his Federal individual income…
2Cases cited9 opinions
- Glenn Weible and Patricia Weible v. United StatesCourt of Appeals for the Ninth Circuit · 1957
- Marsman v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1953
- Adams v. CommissionerUnited States Tax Court · 1966
- Marsman v. CommissionerUnited States Tax Court · 1952
- Patino v. CommissionerUnited States Tax Court · 1949
4 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Maclean v. CommissionerUnited States Tax Court · 1980
- Siddiqi v. CommissionerUnited States Tax Court · 1978
- Budhwani v. CommissionerUnited States Tax Court · 1978
- Maclean v. CommissionerUnited States Tax Court · 1980
- Quidwai v. CommissionerUnited States Tax Court · 1984
1 more not listed; retrieve them via the Exa API.