Footnote 964

See, e.g., United States v. 100.80 Acres of Land (Parrish), 657 F. Supp. 269, 276 (M.D.N.C. 1987) (rejecting valuation of real estate appraiser whose expertise did not extend to minerals); see also USPAP Competency Rule; cf. United States v. Sowards, 370 F.2d 87, 92 (10th Cir. 1966) (“owner’s qualification to testify does not change the ‘market value’ concept and permit him . . . to establish a value based entirely upon speculation”).