Per Curiam.
Junaid Gulzar was convicted of wire fraud and sentenced to a below-Sentencing Guidelines term of 18 months' imprisonment. Central to the Guidelines calculations was the determination of the amount of the victim's "loss." A fraud defendant's offense level is increased under U.S.S.G. § 2B1.1(b)(1) if the "loss" amount exceeds $6,500. At...
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