Formal Comments on EOIR Docket No. 18-0002, NPRM: Procedures for Asylum Withholding of Removal; Credible Fear and Reasonable Fear Review

Formal Comments re: EOIR Docket No. 18-0002, NPRM: Procedures for Asylum Withholding of Removal; Credible Fear and Reasonable Fear Review. Submitted via www.regulations.gov July 15, 2020

8 Pages Posted: 27 Apr 2021

See all articles by Christine Speidel

Christine Speidel

Villanova University Charles Widger School of Law

Anna Gooch

affiliation not provided to SSRN

Date Written: July 15, 2020

Abstract

The Villanova Federal Tax Clinic (the Clinic) submits these comments in response to the above Notice of Proposed Rulemaking published jointly by the U.S. Department of Homeland Security, United States Citizenship and Immigration Services; and by he Department of Justice, Executive Office for Immigration Review.

The Clinic represents low-income individuals in southeastern Pennsylvania in tax controversy matters against the Internal Revenue Service (IRS). We also conduct educational activities on federal tax topics for low-income taxpayers, individuals who speak English as a second language, and nonprofit service providers. our clients often need tax filing help, and we regularly provide clients and callers with information and referrals for tax filing help. Through our decades-long work with taxpayers, nonprofit community service providers, and through interactions with the IRS, the Clinic sees firsthand the challenges that individuals face in attempting to resolve their tax problems, and how difficult achieving tax compliance can be.

Suggested Citation

Speidel, Christine and Gooch, Anna, Formal Comments on EOIR Docket No. 18-0002, NPRM: Procedures for Asylum Withholding of Removal; Credible Fear and Reasonable Fear Review (July 15, 2020). Formal Comments re: EOIR Docket No. 18-0002, NPRM: Procedures for Asylum Withholding of Removal; Credible Fear and Reasonable Fear Review. Submitted via www.regulations.gov July 15, 2020, Available at SSRN: https://ssrn.com/abstract=3834701

Christine Speidel (Contact Author)

Villanova University Charles Widger School of Law ( email )

299 N. Spring Mill Road
Villanova, PA 19085
United States

Anna Gooch

affiliation not provided to SSRN

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