See Matter of Huang, 19 I. & N. Dec. at 750 n. 1 (“Abandonment of lawful permanent resident status of a parent is imputed to a minor child who is subject to the parent's custody and control.”); Matter of Zamora, 17 I. & N. Dec. 395, 396 (BIA 1980) (“We hold that this voluntary and intended abandonment by the mother is imputed to the applicant, who was an unemancipated minor ... at the time his mother abandoned her lawful resident status.”); Matter of Winkens, 15 I. & N. Dec. 451, 452 (BIA 1975) (holding that “[t]he abandonment of [the parents of petitioner's] permanent resident status is imputed to [petitioner], who was subject to their custody and control” when they abandoned). These decisions are loosely derived from the BIA's prior decision in Matter of Bauer, 10 I. & N. Dec. 304 (BIA 1963). There, the BIA held that no “reentry” under INA § 101(a)(13) was made by the 19–year–old petitioner upon his return to the United States three years after departing this country in the custody and control of his parents.
SeeIn re Zamora, 17 I & N Dec. 395 (BIA 1980); In re Favela, 16 I & N Dec. 753 (BIA 1979); In re Winkens, 15 I & N Dec. 451 (BIA 1975). In re Bauer, 10 I & N Dec. 304 (BIA 1963), is not to the contrary; it was expressly overruled in this regard by Zamora. It makes no difference that Paul accompanied his mother back to Bolivia while Franz and Skarlen left later.