Rivera-Sanchez v. Reno, 198 F.3d 545
(5th Cir. Dec. 30, 1999) (federal illegal entry conviction
of violating INA § 275(a), 8 U.S.C. 1325(a) is outside the
ambit of INA § 101(a)(43)(N), 8 U.S.C. 1101(a)(43)(N), which
is explicitly confined to convictions under INA § 274(a),
8 U.S.C. § 1324(a), and so is not an aggravated felony under
that theory for immigration purposes).