1(g)(4) [a person remains a USC until a decision to reopen proceedings and deny naturalization becomes final]; U.S., v. Clarke, 628 F.Supp.2d 1, 8-9 (D.D.C. 2009) [cannot void citizenship without a final order pursuant to 8 U.S.C. § 1451]. But see Matter of Gonzalez-Muro, 24 I&N Dec. 472 (BIA 2008) [reaffirming Matter of Rossi, 11 I&N Dec. 514 (BlA 1966), distinguishing Costello, and finding that respondent could be removed for crimes he was convicted of while a USC, because he committed the crimes as an LPR, had citizenship revoked because he committed the crimes before naturalization, and obtained citizenship by concealing the activity].Please visit thenyc immigration lawyerswebsite for further information.