Penuliar v. Ashcroft, 395 F.3d 1037 (9th Cir. 2005), carries the torch lit by United States v. Corona-Sanchez, 291 F.3d 1201 (9th Cir. 2002), as follows: the Ninth Circuit found that California Penal Code 484 was not a "theft" offense under INA 101(a)(43)(G) based on the possibility of conviction under Penal Code 484 for aiding and abetting "even if that theory is not specifically charged." Corona-Sanchez excludes a crime from the definition of "theft" offense under INA 101(a)(43)(G) if an aider and abettor may stand convicted as the principal without reference to the underlying theory of aiding and abetting.      In Londono-Gomez v. INS, 699 F.2d 475 (9th Cir. 1983), the Ninth Circuit found that aiding and abetting was not a separate offense, and the BIA cited that decision, distinguished it from misprison of a felony, several times after the aggravated felony statute was created. Although Londono dealt with an earlier version of the statute, 18 U.S.C. 2 explicitly "punishes as a principal one who aids or abets" the commission, arguing that the omission of the verbs aiding & abetting in the removal statute indicates that Congress meant to exclude them, like solicitation. But its more likely that, since aiders and abettors are known to be "punished as principals" they just didnt think it was necessary. On the other hand, Congress specified aiding and abetting in the "reason to believe" ground of inadmissibility, INA 212(a)(2)(C)(i), 8 U.S.C. 1182(a)(2)(C)(i), but did not specify attempt or conspiracy.