Sara Fawk, Note, Eligibility for Section 212(c) Relief from Deportation: Is it the Ground or the Offense, the Dancer or the Dance?, 32 Western New England L. Rev. 417 (2010)(describing circuit split concerning whether to disqualify noncitizen from eligibility for waiver of deportability under former INA 212(c) unless the ground of deportability has a statutory counterpart ground of inadmissibility, with the First, Third, Fifth, Sixth, Seventh, Eighth, Tenth, and Eleventh Circuits determining whether a comparable ground of exclusion exists by looking only at the statutory language of the charged ground of deportation and the language of the ground of exclusion that the respondent claims is comparable, and the Second Circuit which adopted an offense-specific approach in Blake v. Carbone, 489 F.3d 88 (2d Cir. 2007), in which the comparable grounds determination turns not on the language of the grounds but instead on the offense committed by the petitioner; the Ninth Circuit rejected the comparable grounds analysis entirely in Abebe v. Mukasey, 554 F.3d 1203, 1206 (9th Cir. 2009) (en banc)(employ[ing] a[n equal protection] standard of bare rationality and offered a legitimate reason for the different treatment of deportees who are similarly situated to excludees but for a temporary departure from the country"namely, Congress could have limited section 212(c) relief to aliens seeking to enter the country from abroad in order to create an incentive for deportable aliens to leave the country.).