What is the legal test for probable cause for a wiretap warrant?

Under Illinois v. Gates, 462 U.S. 213, 103 S.Ct. 2317, 76 L.Ed.2d 527 (1983), probable cause for a search warrant is established if the "totality-of-the-circumstances" indicate a probability of criminal activity. Id. at 230-32, 103 S.Ct. at 2329. "[P]robable cause is a fluid concept--turning on the assessment of probabilities in particular factual contexts--not readily, or even usefully, reduced to a neat set of legal rules." Id. at 232, 103 S.Ct. at 2329. This same standard applies to wiretap warrants. United States v. Fury, 554 F.2d 522, 530 (2d Cir.1977), cert. denied, 436 U.S. 931, 98 S.Ct. 2831, 56 L.Ed.2d 776 (1978). On appellate review, a determination of probable cause deserves "great deference," and will be upheld so long as there was "a 'substantial basis for ... conclud[ing]' that a search warrant would uncover evidence of wrongdoing." Gates, 462 U.S. at 236, 103 S.Ct. at 2331 (citation omitted); see Nersesian, 824 F.2d at 1306.