In Gilderman v. State Farm Insurance Co., 437 Pa. Super. 217, 649 A.2d 941 (Pa. Super. Ct. 1994), the insured had a replacement cost policy, but was to receive actual cash value before any repairs or replacement. The policy limited recovery to the amount actually incurred in repairing or replacing the damaged property. Id. at 942-43. In that case, a Pennsylvania appellate court considered whether State Farm could deduct contractor overhead and profit from its repair or replacement estimate and offer the insureds an advance check for this lower amount as a payment of actual cash value. Id. at 944. In its analysis, the Gilderman court acknowledged that certain types of property damage may be relatively minor and may not require a general contractor to manage the repairs and that, in such cases, "contractor expenses would not have to be included in repair or replacement costs estimates." Id. at 945. But the court also noted that "there are types of property damage where a homeowner would use the services of a general contractor, . . . especially where there is extensive damage to a home requiring the use of more than one trade specialist." Id. The court found that, in these instances, an insurance company may not deduct contractor fees from the actual cash value when such fees are reasonably expected to occur. Id. And the court extended this rationale to instances when the insured might not actually incur labor costs, i.e., when the insured makes his or her own repairs to a covered loss. See id. Thus, in contrast to Snellen, the Gilderman court found State Farm's automatic deduction of contractor fees improper, holding that "repair or replacement costs include any cost that an insured is reasonably likely to incur in repairing or replacing a covered loss," even if the insured may never make the repairs. Id.