Estate of Cyril I. Magnin, Deceased, Donald Isaac Magnin, Executor - Page 3

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          decedent's oldest son, is the executor of his estate.  Donald               
          Magnin filed a timely Federal estate tax return on behalf of                
          petitioner wherein he elected the alternate valuation date,                 
          December 8, 1988.  Donald Magnin resided in San Francisco,                  
          California, at the time he filed the estate tax return.                     

          Background                                                                  

               Cyril's father, Joseph Magnin (Joseph), was born in London,            
          England, on December 27, 1868.  Joseph was the third child of               
          Isaac and Mary Ann Cohen Magnin (Mary Ann), who emigrated from              
          England to San Francisco in 1875.  In 1877, Mary Ann established            
          I. Magnin, a fine clothing store for women.                                 
               Joseph started working for I. Magnin when he was a teenager.           
          In 1898, he married Charlotte Davis (Charlotte), the head                   
          milliner at I. Magnin.  This caused family tensions between                 
          Joseph and his mother.  Mary Ann ran I. Magnin with an iron hand            
          and had a strict rule against family members' fraternizing with             
          employees.  Cyril was born the next year on July 6, 1899.  During           
          the years 1893 to 1913, Joseph was being passed over by Mary Ann            
          for responsible management positions with I. Magnin in favor of             
          his younger brothers.                                                       
               Joseph left I. Magnin in 1913 and invested in a store, which           
          was organized as a corporation by the name of "Newman, Magnin &             
          Co." (Newman-Magnin).  Similar to I. Magnin, Newman-Magnin                  
          specialized in the sale of women's clothing.  In 1918, Joseph               




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