De Araujo v. Ashcroft, ___ F.3d ___, 2005 WL 418200 (1st Cir. Feb. 23, 2005) (court of appeals lacked jurisdiction to review whether conviction constituted an aggravated felony because issue was not raised before court in a timely filed petition for review; BIA decision became final when the BIA dismissed the appeal from the IJs removal order, under 8 C.F.R. 241.1 ("An order of removal made by the immigration judge at the conclusion of proceedings under section 240 of the Act shall become final ... [u]pon dismissal of an appeal by the Board of Immigration Appeals...."); petitions for review addressed to the court of appeals from BIA orders must be filed "not later than 30 days after the date of the final order of removal." 8 U.S.C. 1252(b)(1); this time limit is "a strict jurisdictional requirement." Ven v. Ashcroft, 386 F.3d 357, 359 (1st Cir.2004) (quoting Zhang v. INS, 348 F.3d 289, 292 (1st Cir.2003)).