The Board of Immigration Appeals has determined that a federal conviction for unlawfully selling or otherwise disposing of a firearm or ammunition is not a deportable firearms offense. The BIA found the statute overbroad both because it involves offenses involving ammunition, and not firearms, and because disposing of a firearm does not require a transfer of money. The BIA further concluded that the statute is indivisible, and therefore, a conviction under the statute will never trigger firearms-related deportability.
The full text of Matter of Ortega-Quezada can be found here: