Valansi v. Ashcroft, 278 F.3d 203 (3d Cir.
Jan. 23, 2002) (federal conviction for embezzling, in violation
of 18 U.S.C. § 656, in excess of $400,000 in cash and checks
from employer was not a fraud offense aggravated felony as
defined in section INA § 101(a)(43)(M)(i), 8 U.S.C. 1101(a)(43)(M)(i),
for immigration purposes).