PER CURIAM.
This income tax case was heard and decided upon stipulated facts as follows. The question at issue was were the shredder and crane "placed in service" prior to the close of plaintiff's fiscal year ending July 31, 1975, within the meaning of 46(c)(1) of the Internal Revenue Code of 1954 and Treasury Regulation § 1.167(a)(10)(b).
The District Court decided this question in reliance on Sears Oil Co. v. Commissioner,
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