The following excerpt is from U.S. v. Harper, 32 F.3d 1387 (9th Cir. 1994):
This approach works rather well in cases of theft and outright destruction of property. It is an excellent indicator of the harm to the victim and of the gain to the offender. Similarly, if the victim is relieved of cash, it is often easy to see that the amount of cash is the value of what was taken, whether it was taken by theft, destruction or fraud. See United States v. Wilson, 993 F.2d 214, 217 (11th Cir.1993).
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