Baetjer , 143 F.2d at 392 n.2; see, e.g. , Sharpe v. United States , 112 F. 893, 896 (3d Cir. 1902), aff’d sub nom. Sharp v. United States , 191 U.S. 341 (1903) (“proper to include the damages in the shape of deterioration in value which will result to the residue of the tract from the occupation of the part so taken”); United States v. Miller , 317 U.S. 369, 376 (1943) (“compensation . . . includes any element of value arising out of the relation of the part taken to the entire tract”); cf. United States v. 105.40 Acres of Land in Porter Cty. , 471 F.2d 207, 211 n.8 (7th Cir. 1972) (“It might be argued that recovery of damages arising from a) the relation of the ‘remainder tract’ to the whole, and b) the relation of the ‘condemned tract’ to the whole, have both been ‘loosely spoken of ’ and treated as severance damages.” (quoting Miller , 317 U.S. at 376)); Ga.-Pac. Corp. v. United States , 640 F.2d 328, 336 (Ct. Cl. 1980) (per curiam).