Footnote 421
E.g., Palazzolo, 533 U.S. at 631 (“the difficult, persisting question of what is the proper denominator in the takings fraction”); Penn Cent. , 438
E.g., Palazzolo, 533 U.S. at 631 (“the difficult, persisting question of what is the proper denominator in the takings fraction”); Penn Cent. , 438
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