See Ga.-Pac. Corp. v. United States , 640 F.2d 328, 336-37 (1980) (per curiam); cf. United States v. Va. Elec. & Power Co. , 365 U.S. 624, 632 (1961) (before and after method is “an acceptable method of appraisal, indeed the conventional method”). As noted, the Fifth Circuit “requires the exclusive use of the before-and-after method of valuation.” United States v. 8.41 Acres of Land in Orange Cty. , 680 F.2d 388, 392, n.5 (5th Cir.