What is the test for making a restitution order for abuse of power?

We review a restitution order for abuse of discretion. United States v. Boccagna, 450 F.3d 107, 113 (2d Cir. 2006). The district court has "broad discretion" to make a "reasonable estimate" of actual loss "based on the evidence before it," United States v. Milstein, 481 F.3d 132, 137 (2d Cir. 2007), and we review those estimates "deferentially." Boccagna, 450 F.3d at 113. At the same time, federal courts lack the inherent power to order restitution, and the government bears the burden to show necessity by a preponderance of the evidence. 18 U.S.C. 3664(e).