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Do key date coins get a bump in grade?

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JTO

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1934-S S$1 in MS-65 or should it be 64.

I must admit that the coin might have graded a 64 if it were a Philadelphia issue. I think that the key or semi key dates get a slight "benefit of the doubt" so that the grading services can keep them their holders. This, i my opinion is more common with the Heritage-PCGS connection but I could be wrong... what do you all think?

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