Bobb v. Atty Gen. of the United States, __ F.3d __ (9th Cir. Aug. 3, 2006) (DHS was not required to charge federal conviction of check forgery, in violation of 18 U.S.C. 510(a)(2), as an aggravated felony "forgery" offense under INA 101(a)(43)(R), since the various aggravated felony definitions are not necessarily mutually exclusive), but see, Ki Se Lee v. Ashcroft, 368 G.4f 218 (3d Cir. 2004) (INA 101(a)(43)(M)(i), aggravated felony fraud, and INA 101(a)(43)(M)(ii), aggravated felony fraud against government, are mutually exclusive, since to read the statutes otherwise would render (M)(ii) meaningless).
http://caselaw.lp.findlaw.com/data2/circs/3rd/052891p.pdf