Arguelles-Olivares v. Mukasey, 526 F.3d 171 (5th Cir. April 22, 2008), revised opinion, (5th Cir. Feb. 5, 2009) (immigration judge properly considered presentence report to establish loss to victim in excess of $10,000, in finding federal conviction of knowingly filing a false tax return, in violation of 26 U.S.C. 7206(1), constituted a fraud offense aggravated felony, under INA 101(a)(43)(M)(i), 8 U.S.C. 1101(a)(43)(M)(i), with a loss to the victim in excess of $10,000, for purposes of triggering deportability, since this factor invites consideration of evidence outside the record of conviction of the traditional categorical analysis), following James v. Gonzales, 464 F.3d 505, 510-11 (5th Cir. 2006); accord, Singh v. Ashcroft, 383 F.3d 144, 159-61 (3d Cir. 2004).