4.4.4.5. Further Guidance.The income capitalization approach to value in the appraisal of real estate generally—not only in the context of federal acquisitions—has evolved significantly in recent decades.627 The basic parameters for its use for just compensation purposes can be found in Supreme Court cases such as United States v. Toronto, Hamilton & Buffalo Navigation Co.,628 and several recent circuit court cases cited in this Section provide more concrete analysis.629 The district court rulings affirmed by or on remand from three recent circuit court opinions are also instructive—see the Gettysburg Tower litigation in the Third Circuit, the Amexx litigation in the Second Circuit, and the Piza-Blondet litigation in the First Circuit.630 The Parrish case, an older district court ruling from the Middle District of North Carolina, provides a sound analysis of the appropriate determination and use of royalty rates in estimating market value.631 Also informative are In re Cool, a bankruptcy case discussing the income approach based on legal principles derived from eminent domain case law,632 and Denver v. Quick, a state law case—cited with approval by a number of federal circuit courts—analyzing the consideration of income derived from the land itself.633