Footnote 267
United States v. Miller , 317 U.S. 369, 375 (1943); see also Fuller , 409 U.S. at 491. In developing the market value standard as the measure of just compensation, the federal courts have employed terms such as value, market value, fair market value , and market value fairly determined interchangeably; the adding of adjectives such as fair or cash to the term market value does not alter its meaning for federal acquisition purposes. See Miller , 317 U.S. at 374 & nn.10-14 (citing cases).