See Kimball Laundry , 338 U.S. at 15 (“It is a difference in degree wide enough to require a difference in result.”); United States ex rel. Tenn. Valley Auth. v. Powelson , 319 U.S. 266, 281-85 (1943); Monongahela Nav. Co. v. United States , 148 U.S. 312, 326-29, 343-44 (1893); Stipe , 337 F.2d 818 (rejecting valuation based on business income where owner’s loss was “due to the destruction or frustration of his business, and not the taking of the property” because “[s]uch losses are not compensable”).