If highly developed metropolitan conditions are present, new business will be acquired in the hypothetical starting plant much more rapidly than where such conditions are yet to be developed. For this reason the problem cannot be based on the early growth of the same plant, and, there being no exact duplicate of conditions in existence elsewhere, the estimate of time required for the business development period is purely speculative, and must be assumed with great care and judgment, else injustice may be done to one party or the other in the resulting going value. It is interesting to note that, in the Michigan appraisal, the allowance of a percentage for contingencies was bitterly contested by the railroads as improper. Probably every appraiser who has been connected with rate cases has seen this same item strenuously insisted on by the corporations. The author's query: should a corporation which is compelled to abandon appliances while yet serviceable, in response to public clamor, be allowed any item of value in the appraisal on account of such appliances, seems to be best answered in the negative. If the appraisal is for the basis of making rates, the corporation is fully compensated by the fact that its depreciation account provides for all abandoned machinery, and the average past depreciation is usually considered a fair criterion of the future. If the appraisal is for purposes of taxation, it would seem improper to levy tax on abandoned or rejected machinery or equipment. If the appraisal is to determine the present value of a property for sale under condemnation proceedings, it is likewise difficult to conceive any reason for allowing any present value on account of property abandoned or rejected, and, indeed, if such abandoned material had any value at the time of its removal, it is more than likely that such value was converted into cash at that time. The statement that no appraiser would be justified in placing a going concern value on a property 3 years old, or 10 years old, unless the net earnings were such as to indicate that the property had a commercial value in excess of the physical property, is questionable. "Commercial value" is not exactly synonymous with "going concern value," for, as usually considered, the term "going concern value" represents the difference between a dead structure and a live one. A property might be compelled to operate temporarily at rates insufficient to return the legal rate of interest on the physical value of the property, and while this condition continued, its commercial value would be less than its physical value, and yet this same property is worth more while running than if operation ceased and the business was allowed to die.