(C)  Offenses “Related to” Another Offense.  Many, but not all, specific aggravated felony categories have parentheticals describing the offenses contained in specific statutes as “relating to” a given offense.  To read the “related to” language in the definition of offenses relating to failure to appear,[396] for example, to include aiding and abetting offenses would render meaningless the “conspiracy or attempt” language applicable to all aggravated felonies.[397]  See § 4.37, infra.

[396] INA § 101(a)(43)(T), 8 U.S.C. § 1101(a)(43)(T).

[397] INA § 101(a)(43)(U), 8 U.S.C. § 1101(a)(43)(U).

AGGRAVATED FELONY - THEFT OFFENSE - AUTO THEFT - AIDING AND ABETTING
Gonzales v. Duenas-Alvarez, ___ U.S. ___, 2007 WL 98723 (Jan. 17, 2007) (California conviction of unlawful taking of a vehicle, in violation of Vehicle Code 10851(a), constituted theft offense aggravated felony, under INA 101(a)(43)(G), 8 U.S.C. 1101(a)(43)(G), since the crime of "aiding and abetting" a theft offense is included within the substantive offense).