4.4.2.4.7. Sales After the Date of Valuation.Sales that occurred after the date of valuation may be considered if they are not otherwise incompetent as evidence of value.529 In the words of the Eleventh Circuit: “While post-taking sales are not automatically appropriate evidence of comparable value, neither are they automatically inappropriate.”530 But post-acquisition sales may be tainted by government project influence and reflect elements of value that cannot be considered under the scope of the project rule.531 As a result, before considering such sales, the appraiser must analyze “whether the sales are tainted and how much the taint distorts true market value . . . .”532 

In partial acquisitions, post-acquisition sales that reflect the influence of the government project can be highly comparable in valuing the remainder property after acquisition.533 For example, “[s]uch sales should be particularly useful when the measure of [compensation] … is the difference between the market value before and after imposition of an easement.”534