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
Musheer H. Siddiqi, Petitioner v. Commissioner of Internal Revenue, Respondent
Siddiqi v. Commissioner
Docket No. 1632-77
United States Tax Court
70 T.C. 553; 1978 U.S. Tax Ct. LEXIS 90;
July 18, 1978, Filed
Decision will be entered for the respondent.
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…
2Cases cited4 opinions
- Adams v. CommissionerUnited States Tax Court · 1966
- Friedman v. CommissionerUnited States Tax Court · 1961
- Budhwani v. CommissionerUnited States Tax Court · 1978
- Siddiqi v. CommissionerUnited States Tax Court · 1978