Kawashima v. Holder

Summary

The Court held that tax crimes under 26 U.S.C. §§ 7206(1) and (2) involving fraud or deceit with losses exceeding $10,000 qualify as aggravated felonies for deportation. This outcome follows from applying a categorical approach to the statute's elements rather than specific facts. Justice Ginsburg dissented, arguing that Clause (i) does not address tax offenses to avoid rendering Clause (ii) superfluous.