United States v. Benitez-Perez367 F.3d 1200 (9th Cir. May 20, 2004) ("sentence imposed" for purposes of 2L1.2(b)(1) means the actual sentence imposed by the judge; parole [unlike probation] is not to be considered in determination of the "actual sentence imposed").
http://caselaw.lp.findlaw.com/data2/circs/9th/0310419p.pdf