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U.S. v. Allender, No. 94-3200 (7th Cir.) (62 F.3d 909) (August 4, 1995) (Judge Daniel A. Manion)

Here the Court explained that Application Note 7 (now Application Note 8(b)) refers to the speculative "opportunity cost" of misappropriated funds. "It does not refer to a guaranteed specific rate of return that a defendant contracts of promises to pay. This is the interpretation taken by several other circuits.".

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