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.