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Pakistan because of his poor health. On December 24, 1986,
decedent traveled to Pakistan to visit his family and to
formalize the agreement with Chrag and Mohammed Ali for the
division of the partnership property.
Before leaving for Pakistan, decedent applied for a permit
to reenter the United States. A reentry permit shows that the
person to whom the permit is issued is returning to the United
States from a temporary visit abroad and relieves the person from
the necessity of securing a visa from an American Consul before
returning to the United States. On January 7, 1987, the
Sacramento office of the Immigration and Naturalization Service
issued decedent a permit to reenter the United States without a
visa (reentry permit); the reentry permit was valid for multiple
entries and had an expiration date of January 6, 1989. The
following "Important Information" concerning the effect of
claiming nonresident alien status for Federal income tax purposes
is provided on the last page (page 16) of the reentry permit:
An alien who has actually established residence in the
United States after having been admitted as an
immigrant or after having adjusted status to that of an
immigrant, and who is considering the filing of a
nonresident alien tax return or the non-filing of a tax
return on the ground that he is a nonresident alien,
should consider carefully the consequences under the
immigration and naturalization laws if he does so.
If an alien takes such action, he may be regarded
as having abandoned his residence in the United States
and as having lost his immigrant status under the
immigration and naturalization laws. As a consequence
he may be ineligible for a visa or other document for
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