Footnote 439

The sales comparison approach was formerly called the market data approach, a problematic term because “[i]n essence, all approaches to value (particularly when the purpose of the appraisal is to establish market value) are market data approaches since the data inputs are presumably market derived.” b yrl n. b oyce, r eAl e sTATe A pprAisAl T erminology136 (1st ed. 1975) (defining “market data approach”);