E.g., Winston v. United States, 342 F.2d 715, 724 (9th Cir. 1965). In particular, the phrases “reproduction cost new less depreciation” and “replacement cost new less depreciation” often appear with little precision or explanation. Nonetheless, “[i]n appraisal the distinction between reproduction cost and replacement cost is quite clear.” eATon, supra note 16, at 161.