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proof, or general to choice proof, and he had calculated that the
total value of these coins was $7,635,000 as of July/August 1991.
The decedent died on March 18, 1992. Shortly thereafter,
Mr. Goldberg asked two independent grading services, Professional
Coin Grading Service (PCGS) and Numismatic Grading Co. (NGC), to
grade the 191 coins. Contrary to the decedent's expressed views,
Mr. Goldberg believed that the 191 coins would realize more at
auction if they were graded by an independent grading service.
In March 1992, PCGS graded all 191 coins, but for the 6-piece
Amazonian set and three other coins which PCGS refused to grade,
and PCGS encapsulated the graded coins into a tamper-proof
plastic container. One month later, all 191 coins, but for the
6-piece Amazonian set, were graded by NGC after NGC had removed
the coins from their containers. The following chart shows the
number of coins that received each grade from PCGS and NGC:
Grade Number of Coins--PCGS Number of Coins--NGC
60 0 1
61 3 0
62 17 12
63 69 21
64 78 71
65 12 51
66 1 22
67 1 5
68 0 1
69 1 1
Total 182 185
On May 4, 1992, Superior communicated the results of the
PCGS grading to Robert A. Levinson (Mr. Levinson), the estate's
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