Matter of Vella, 27 I&N Dec. 138 (BIA 2017) (a noncitizen has previously been admitted to the United States as an LPR within the meaning of INA 212(h) if he or she was inspected, admitted, and physically entered the country as an LPR at any time in the past, even if such entry is not the most recent, and therefore is ineligible for a waiver of inadmissibility under INA 212(h)).
CCDOI 22.21

NOTE: This means that while an LPR may not be subject to the aggravated felony or 7 year bars to an INA 212(h) waiver if they adjusted status within the United States, such persons would become subject to the bar if they depart the U.S. and reenter via their LPR status.