Footnote 586

47.14 Acres in Polk, 674 F.2d at 726; see United States v. 69.1 Acres of Land (Sand Mountain), 942 F.2d 290, 293-94 (4th Cir. 1991) (“These valuations almost always achieve chimerical magnitude, because, in the mythical business world of income capitalization, nothing ever goes wrong.”); cf. United States v. Whitehurst, 337 F.2d 765, 772 (4th Cir. 1964) (“[A] change of even a fraction of one per cent will produce a surprisingly material change in the result.”); eATon, supra note 16, at 174 (“To address the increasing complexity of real estate investment and financing, and the inflationary and recessionary trends of the 1970s and 1980s, more sophisticated investment analysis was developed. New techniques of analysis probably contributed in some degree to the financial woes of the banking industry, not because these techniques are flawed, but because they can easily be misused and manipulated.”).