The run of proof 1938 Lincoln cents is much higher than any single-issue production of proof coins that came before, and increasing mintages became the case for proof coinage of the 1930s and early 1940s, with most successive years bringing higher proof mintages than the previous. And while the 1938 proof Lincoln cent is not really a scarce issue by mintage, it is more difficult to find in the higher grades, particularly PR67 and above.
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