prospective purchasers or condemnors affects market value, it is to be taken into account" (292 U.S. at 255-57). Consistent with the economic principles identified above, the Court has held that an evaluation of comparable sales represents the most reliable way to determine the amount a willing buyer would have agreed to pay a willing seller had the property been transferred on the open market. As the Court observed in Kimball Laundry, "If exchanges of similar property have been frequent, the inference is strong that the equivalent arrived at by the haggling of the market would probably have been offered and accepted, and it is thus that the 'market price' becomes SO important a standard of reference" (338 U.S. at 6). Other evaluation methodology may be required when the property being val- ued is traded SO infrequently that, in effect, no market for it exists. 37 In the absence of comparable sales, when valuing commercial property the Court has sanctioned the income capitalization approach, in which market value is equal to the net present value of the property's projected income.38 Although this approach has advan- tage of being based on data derived from actual market transactions, the Court 35 See Miller, 317 U.S. at 374; Lutheran Synod, 441 U.S. at 511; Kirby Forest, 467 U.S. at 10. 36 See Almota, 409 U.S. at 474, 477-78. 37 See, e.g., Miller, 317 U.S. at 374; Toronto, Hamilton & Buffalo, 338 U.S. at 402; Kimball Laundry, 338 U.S. at 5; Commodities Trading Corp., 339 U.S. at 123; Lutheran Synod, 441 U.S. at 512; Kirby Forest, 467 U.S. at 10 n. 14; Duncanville Landfill, 469 U.S. at 29. 38 Kimball Laundry, 338 U.S. at 16 ("One index of going-concern value offered by petitioner is the record of its past earnings."); Lutheran Synod, 441 U.S. at 515 ("[T]he uses to which commercial property is put can often be valued in terms of the capitalized earnings produced"). For an Constitutional Limits on the Pricing of Access to Networks has recognized that it does carry some risks. Estimates of value based on income cap