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
Amirali Budhwani, Petitioner v. Commissioner of Internal Revenue, Respondent
Budhwani v. Commissioner
Docket No. 9722-76
United States Tax Court
70 T.C. 287; 1978 U.S. Tax Ct. LEXIS 118;
May 22, 1978, Filed
Decision will be entered for the respondent.
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…
2Cases cited10 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
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