when it's a shelters game and you draw two with hovel and you're like should I get an estate, first check if there is Baths
And regardless of whether it's there, don't get the Estate.
Unless you are able to Inherit something fun like Iw, Shepard, or Sir Martin. (Bonus points if you Inherit on T1/2 via Cursed gold). Or if you have a tight Upgrade deck. Or if you plan to Margrave -> Masq -> B-Crat -> Masq.
But yes, outside of edge cases, it is exceedingly rare to make that be more VP than a Duchy buy from the estate move. Pretty much all the cases where you want to burn the Hov with an estate buy, you just want to buy estates regardless.