Execution of Form 236, "Transfer of Distilled
Spirits In Bond"
Proprietors of distilleries, internal
revenue bonded warehouses, and
1. This Circular is issued to provide advisory instructions governing the execution of Form 236.
2. In all cases covering the transfer of distilled spirits in bond,
the regulations in 26 CFR Parts 220, 221, and 225 require the proprietor to
enter a complete description of such spirits on Form 236. Part 3 of Form
236 provides for this description and for the signature of the proprietor.
3. Where the spirits to be transferred are contained in packages,
such regulations also require the proprietor to certify on all copies of
Form 236 as to the accuracy of the description of the packages and the
removal thereof. Part 4 of Form 236 provides for this certification and for
the signature of the proprietor under penalties of perjury. Thus, where
packages of distilled spirits are transferred, the question arises as to the
necessity for the proprietor's signature on both parts 3 and 4 of Form 236.
4. Where distilled spirits to be transferred in bond are contained in
packages and the consignor proprietor is required to sign part 4 of Form 236,
he need not sign part 3 of Form 236, since execution of part 4 attests to the
accuracy of part 3.
5. Inquiries in regard to this industry circular should refer to the
number thereof and should be directed to the appropriate Assistant Regional
Commissioner, Alcohol and Tobacco Tax.
Dwight E. Avis
Director, Alcohol and Tobacco Division