The Board of Immigration Appeals has determined that the generic definition of a receipt of stolen property does not require that the property be obtained by common law theft. Even if the property is obtained by fraudulent means, the conviction can qualify as a receipt of stolen property aggravated felony. Thus, a conviction under section 496(a) of the California Penal Code qualifies as a receipt of stolen property aggravated felony if a sentence of at least one year of imprisonment is imposed.
The full text of Matter of Alday-Dominguez can be found here:
https://www.justice.gov/eoir/page/file/970806/download