Li v. Ashcroft, 389 F.3d 892 (9th
Cir. Nov. 19, 2004) (federal conviction of conspiracy to defraud
the United States, in violation of 18 U.S.C. § 371, is divisible
with respect to the fraud offense aggravated felony defined
in INA § 101(a)(43)(M)(i), 8 U.S.C. 1101(a)(43)(M)(i), since
it does not require proof of any specific amount of monetary
loss and so does not automatically satisfy the element of
this aggravated felony definition requiring a loss to the
victim(s) in excess of $10,000, so the record of conviction
must be examined to determine whether the conviction falls
within the definition).