United States v. Certain Interests in Prop. in Champaign Cty., 271 F.2d 379, 382 (7th Cir. 1959); accord United States v. 55.22 Acres of Land in Yakima Cty., 411 F.2d 432, 435 (9th Cir. 1969); United States v. 49,375 Square Feet of Land in Manhattan (252 Seventh Ave.), 92 F. Supp. 384, 387-88 (S.D.N.Y. 1950), aff ’d sub nom. United States v. Tishman Realty & Constr. Co., 193 F.2d 180 (2d Cir. 1952) (per curiam) (affirming on opinion of trial court) (“[The cost approach] is in itself absurd in the ordinary case, because even in ordinary times it is ridiculous to suppose that anyone would think of reproducing this or any like property, and that same thing would be true in the vast majority of cases, I should think.”); seeeATon, supra note 16, at 159 (noting “flagrant misuse of the approach by appraisers [who err] from lack of knowledge [or] use the cost approach to intentionally exaggerate the market value of property”).