Footnote 368
8.41 Acres in Orange , 680 F.2d at 394 n.8 (citing United States ex rel. Tenn. Valley Auth. v. Powelson , 319 U.S. 266 (1943)); United States v. Mattox , 375 F.2d 461, 463-64 (4th Cir. 1967) (“there must exist a reasonable probability that the separate tracts would have been combined for such integrated use”); Cole Inv. Co. v. United States, 258 F.2d 203, 205 (9th Cir. 1958) (finding no unity of use where evidence “would only show a planned unity of use”); cf. Powelson , 319 U.S. at 284 (“the possibility or probability of [a future] action, so far as it affects present values, is a proper subject for consideration in valuing property for purposes of a condemnation award” (emphasis added)).