Kuhali v.Reno, 266 F.3d 93 (2nd Cir. 2001) (ammunition was not a firearm or destructive device). The Ninth Circuit suggests that ammunition-related offenses are not deportable under the firearms ground. See Malilia v. Holder, 632 F.3d 598, 603 (9th Cir. 2011) (Because only the improper delivery of a firearms would constitute a removable offense, a violation of 922 is not categorically a removal [firearms] offense. For instance, improperly delivering ammunition would not render the alien removal under 1227.)