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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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