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).