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SIDDIQI v. COMMISSIONER

Docket No. 1632-77.

70 T.C. 553 (1978)

MUSHEER H. SIDDIQI, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 18, 1978.

Attorney(s) appearing for the Case

Eugene D. Seligmann, for the petitioner.

Charles L. Eppright, for the respondent.

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(1)(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...

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