Velazquez-Herrera v. Gonzales, 466 F.3d 781, 783 (9th Cir. 2006) (internal quotation marks omitted) (BIA dictum is not a statutory interpretation that carries the force of law, and thus is not entitled to deference); cf. United States v. Johnson, 256 F.3d 895, 914-15 (9th Cir. 2001) (a holding, as opposed to dicta, is reached after reasoned consideration, in which the court undeniably decided the issue, after argument from both parties).