Pete Rose, former Major League Baseball star and manager, pled guilty on April 22, 1990,to two charges of filing false income tax returns not showing income he received from selling autographs, memorabilia, and from horse racing winnings. On July 20, 1990, Rose was sentenced to five months in the medium security Prison Camp at the United States Penitentiary in Marion, Illinois and fined $50,000. He was released on January 7, 1991 after having paid $366,041 in back taxes and interest. According to INA § 101(a)(43)(M), this conviction is likely an aggravated felony. The statute defines an aggravated felony as an offense that “(i) involves fraud or deceit in which the loss to the victim or victims exceeds $ 10,000; or (ii) is described in section 7201 of the Internal Revenue Code of 1986 [26 USCS § 7201] (relating to tax evasion) in which the revenue loss to the Government exceeds $ 10,000.” The Board of Immigration Appeals has recently held that the loss can be determined from evidence outside of the record of conviction. Mr. Rose had to pay $366,041 in back taxes, probably probative of a loss of more than $10,000.