United States v. Iqbal, No. 08-2262-cr (2d Cir. March 31, 2009) (found here)
On appeal, Iqbal challenged his 24 month sentence, asserting that the district court's loss calculation was erroneous. Specifically, the district court determined that the loss amount exceeded 400,000 based on testimony provided at a Fatico hearing that the fraud at issue involved fraudulent credit card charges of $413,838.02.
It is well established that a court "need only make a reasonable estimate of loss." U.S.S.G. § 2B1.1 cmt. 3(C). And to that the Second Circuit added the following nugget: "We have never required that a district court find a loss amount to the penny, so long as the amount it estimates based on the record is not clearly erroneous."