What is the current state of the law on minimum tax loss?

This approach to assessing minimum tax loss is also consistent with other guideline provisions which specify that loss "need not be determined with precision," but may instead be based upon "reasonable estimates given available information." See e.g. Application Note 8 to Sec. 2F1.1 (fraud losses). Further, at least one other court rejected a similar attempt to restrict the scope of relevant conduct in tax loss cases by reference to other potential tax code liability limits. See e.g., United States v. Pierce, 17 F.3d 146, 150 (6th Cir.1994) (civil tax statute of limitations does not restrict scope of relevant conduct under guidelines for tax evasion).