Footnote 587

United States v. 103.38 Acres of Land in Morgan Cty. (Oldfield), 660 F.2d 208, 214 (6th Cir. 1981); accord Sand Mountain, 942 F.2d at 294 (“As the seminal case on the subject stated, ‘it would require the enumeration of every cause of business disaster to point out the fallacy of using this method of arriving at just compensation.’” (quoting United States ex rel. Tenn. Valley Auth. v. Indian Creek Marble Co., 40 F. Supp. 811, 822 (E.D. Tenn. 1941))); see Parrish, 657 F. Supp. at 274 (“[D] angers present in the discounted royalty method [include] the dangers of speculation about future market demand and the vagaries of operating a business.”).