Yes, and those routinely get the Altered Stock designation from PSA that would leave them as returned ungraded or Authentic Altered slabbed.
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PWCC: The Fish Stinks From the Head
PSA: Regularly Get Cheated
BGS: Can't detect trimming on modern
SGC: Closed auto authentication business
JSA: Approved same T206 Autos before SGC
Oh, what a difference a year makes.
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