MEMORANDUM **

Marisa Garcia-Villareal is a native and citizen of Mexico who petitions for review of a decision of the Board of Immigration Appeals (“BIA”) holding that her Califor *89 nia conviction for welfare fraud rendered her ineligible for cancellation of removal under 8 U.S.C. § 1229b(b). She contends that she is eligible for cancellation because § 1229b(b)(1)(C)’s reference to 8 U.S.C. § 1227(a)(2) does not apply to her as an alien who was never admitted.

Garcia-Villareal’s argument is foreclosed by this court’s decision in Gonzalez-Gonzalez v. Ashcroft, 390 F.3d 649 (9th Cir. 2004). In Gonzalez-Gonzalez, we rejected the argument that “crimes of domestic violence” listed in § 1227(a)(2) did not apply to the alien in that case because he had never been admitted. Id. at 653. We held that § 1229b(b)(1)(C)’s reference to an alien who “has not been convicted of an offense under section ... 1227(a)(2)” clearly meant a conviction “described under” that section, and therefore that an alien can be barred from cancellation by a conviction for an offense described under § 1227(a)(2) even if the alien is not deport-able under that section. Id. at 652.

We also recognized in Gonzalez-Gonzalez that Chevron deference to the BIA would apply if § 1229b(b)(1)(C) were ambiguous. Id. at 651. Here, even if we were to hold that § 1229b(b)(1)(C) is ambiguous insofar as it may apply to a person seeking to qualify for the petty offense exception to a crime involving moral turpitude under § 1182(a)(2)(A)(ii)(II), the same Chevron deference would apply. The BIA has recently issued a published opinion holding that the petty offense exception is irrelevant when an alien is otherwise ineligible for cancellation because of a conviction for a crime described under § 1227(a)(2). See Matter of Almanza-Arenas, 24 I. & N. Dec. 771, 776 (BIA 2009). As the BIA’s interpretation of the statute is reasonable, Garcia-Villareal’s attempt to distinguish Gonzalez-Gonzalez as dealing with a separate provision in the deportability statute fails.

The petition for review is DENIED.