922 F.2d 1385, 1392 (9th Cir.1991); see also United States v. Stanley, 12 F.3d 17, 20 (2nd Cir.1993), cert. denied, — U.S. —, 114 S.Ct. 1572, 128 L.Ed.2d 216 (1994). The estimate of a fraud loss “must reflect economic reality, [and] the loss figure need not be precise but may be a reasonable estimate.” United States v. Khan, 969 F.2d 218, 221 (6th Cir.1992) (internal quotations omitted). While the term “intended loss” is a subjective measure, “probable loss” connotes an objectively-measured harm. See United States v. Sneed, 814 F.Supp. 964, 970 (D.Colo.1993). As the district court correctly noted, insurance claims are frequently inflated. Basing the probable loss on the claim, then, does not reflect economic reality. See United States v. Santiago, 977 F.2d 517, 524 (10th Cir.1992) (<HOLDING>). For example, Chudi Anode’s claim for the
holding that proof of loss is not evidence of extent of loss and insured is not precluded from showing his damages were greater than shown in proof of loss holding the defendant responsible for the greater of the actual or intended loss holding that an intended loss  cannot exceed the loss a defendant could have occasioned if his or her fraud had been entirely successful holding that loss of an arm includes loss of the hand holding that joint and several liability for entire actual loss could have been imposed on each fraud defendant as condition of probation