Siddiqi v. Commissioner
United States Tax Court
Held, a citizen of Pakistan who came to the United States in June 1973 for the purpose of studying architecture, expecting to remain in the United States for 4 1/2 to 5 years to accomplish that purpose, was not a resident of Pakistan in 1975 within the meaning of the United States-Pakistan income tax convention since he was a resident of the United States in that year for Federal income tax purposes.
1Opinion of the Court
OPINION
Scott, Judge:
Respondent determined a deficiency in petitioner’s 1975 Federal income tax of $778.51. The issue for decision is whether, under article XIII(l)(a) of the United States-Pakistan income tax convention, petitioner is exempted from tax on $5,000 of compensation he earned while performing services within the United States.
All of the facts have been stipulated and are found accordingly-
Petitioner is a citizen of Pakistan. He filed a “Nonresident Alien” Federal income tax return for calendar year 1975 with the Internal Revenue Service Center in Philadelphia, Pa. At the time he…
2Cases cited3 opinions
- Adams v. CommissionerUnited States Tax Court · 1966
- Friedman v. CommissionerUnited States Tax Court · 1961
- Budhwani v. CommissionerUnited States Tax Court · 1978
3Cited by3 opinions
- Elghanian v. Comm'rUnited States Tax Court · 2005
- Quidwai v. CommissionerUnited States Tax Court · 1984
- Siddiqi v. CommissionerUnited States Tax Court · 1978