Bruce and Jeanne Korson, et al. - Page 4

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          coin collection (Armin's papers).  Jane Allen died testate in               
          1981 and her children, petitioners Jeanne Korson, Armin B. Allen,           
          and John H. Allen (collectively, the children), received those              
          ledgers, items, and papers by devise.  The children also received           
          papers that their mother compiled, some of which relate to her              
          dispersal of some of the coin collection (the Jane Allen papers).           
          Each of the children was a co-executor of Jane Allen's estate               
          (the estate).  A Federal estate tax return was filed on behalf of           
          the estate and each of the children signed that tax return.  That           
          return did not include Armin's half of the coin ledgers, Armin's            
          half of the photocopy, the Chicago Coin Co. papers, the coin                
          envelopes, the Virgil Brand estate papers, Armin's papers, or the           
          Jane Allen papers as assets of the estate because none of the               
          children believed that those items had any market value.                    
               Jane Allen's estate also included part of the coin                     
          collection.  The executors of the estate devised a marketing plan           
          in an attempt to maximize the value of those coins.  They decided           
          to promote Virgil Brand's name in order to develop his identity             
          as a unique numismatic collector and to publicize his life as               
          well as the coin collection.  To that end, the executors arranged           
          to have a book published in 1983 that profiled Virgil Brand and             
          the coin collection.                                                        








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