Kuhali v.
Reno, 266 F.3d 93 (2d Cir. Sept. 27, 2001) (federal conviction
for conspiracy to export firearms without license, in violation
of 18 U.S.C. § 371 and 22 U.S.C. 2778, constitutes an aggravated
felony under INA § 101(a)(43)(C), (U), 8 U.S.C. 1101(a)(43)(C),
(U), for immigration purposes, since it necessarily exhibits
a business or merchant nature, regardless of any nexus with
commerce as an element of the offense or of a similar "match"
between elements).