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The article examines the U.S. Supreme Court's lack of clarity about the economic projections of the Penn Central test in contrast to recent decisions from the Federal Claims Court and the Federal Circuit Court to show how those courts have advanced the framework of the test and measurement of damages. Some section of this paper review conducted cases to show how these courts have examined and relied on the economic underpinnings of this test in recent years. The U.S. Supreme Court implies that regulatory takings do not require that all value be eliminated before a citizen is entitled to compensation.