Matter of VZS, 22 I. & N. Dec. 1338
(BIA Aug. 1, 2000) (en banc) (California conviction for unlawful
driving and taking of a vehicle in violation of California
Vehicle Code § 10851 is a aggravated felony "theft offense"
under INA § 101(a)(43)(G), 8 U.S.C. 1101(a)(43)(G) since
"theft" for aggravated felony purposes is defined
as a taking of property whenever there is criminal intent
to deprive the owner of the rights and benefits of ownership,
even if the deprivation is less than total or permanent).