In Crossman v. Crossman (95 N.Y. 145 [1884], the Court of Appeals found the interlineation--the insertion of the name of an executor omitted from one of two duplicate original wills--which was duly noted above the attestation clause of the will, preceded execution. Crossman was an unusual case in that the validity of the interlineation was not questioned in the original probate proceeding; indeed, the altered duplicate was not even proffered. Contestants in Crossman commenced their proceeding to invalidate the will after the unaltered duplicate had been admitted to probate. Despite the peculiar posture and narrow holding of Crossman, its impact is broad: it dispels the notion that an alteration to a will is presumed invalid. The Court of Appeals stated: "The claim on the part of the contestants is that the law presumes that this interlineation was made after execution . . . But we do not so understand the law in this State. Where an interlineation, fair upon the face of an instrument, is entirely unexplained, we do not understand that there is any presumption that it was fraudulently made after the execution of the instrument." Crossman v. Crossman, 95 N.Y. 145, 152, 5 Civ. Proc. R. 204 [1884], supra.) The Court of Appeals enunciated factors a surrogate is bound to consider: "Here, from all the circumstances it was, at least for the surrogate, to determine whether this interlineation was made before or after execution; and in making that determination he was bound to consider the handwriting, the color of the ink, the manner of the interlineation, the fact that it was noted at the bottom of the instrument, and that it was made to correspond with the other duplicate. Where an interlineation or erasure in a will is fair upon its face, and it is entirely unexplained, there being no circumstance whatever to cast suspicion upon it, it would not be proper for any court to hold that the alteration was made after execution; but if there are any suspicious or doubtful circumstances growing out of the mode of the alteration, the ink in which it was made, the fact that it was in favor of the party holding the instrument, and that it is not noted at the bottom, then these and all the other circumstances must be submitted as questions of fact to be determined by the court, in deciding whether the alterations were made before execution or not." (Crossman v. Crossman, 95 N.Y. 145, 153-154, 5 Civ. Proc. R. 204 [1884], supra.)