In the thread What’s your favorite “programmer ignorance” pet peeve?, the following answer appears, with a large amount of upvotes:
Programmers who build XML u
Maybe it won't ever happen, but what if your environment switches to XML 2.0 someday? Your string-concatenated XML may or may not be valid in the new environment, but XDocument will almost certainly do the right thing.
Okay, that's a reach, but especially if your not-quite-standards-compliant XML doesn't specify an XML version declaration... just saying.