The following excerpt is from U.S. v. Williams, 111 F.3d 139 (9th Cir. 1997):
6 The Government bears the burden of proving by a preponderance of the evidence the amount of loss caused by the defendant's fraud. See United States v. Howard, 894 F.2d 1085, 1090 (9th Cir.1990) (government has burden of establishing facts needed to calculate base offense level).
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