In a very unusual circumstance, the Sixth Circuit has found a restitution order - based on an itemized “loss” list that contained internal inconsistencies, as well charges not covered by the criminal statute - was insufficient to demonstrate a greater than $10,000 loss to the victim.
The full text of Al-Adily v. Garland can be found here:
https://www.opn.ca6.uscourts.gov/opinions.pdf/23a0058p-06.pdf