Errors on Reports of Withdrawals From
Distilleries and Internal Revenue
Proprietors of distilleries, internal
revenue bonded warehouses, and
1. Considerable difficulty is being experienced because of
errors in original tax gallons on entry and withdrawal forms prepared by proprietors and found by them after completion of the
2. Distillers finding such errors have, in order that their
monthly reports might reflect more accurately actual withdrawals,
been reporting corrected gallonage figures on their monthly reports.
In most instances, proprietors have not prepared amendments of the
daily transaction reports in error and, therefore, the figures on
the monthly reports are not in agreement with those appearing on
the entry and withdrawal forms in the office of assistant regional commissioners. This has resulted in considerable correspondence between the assistant regional commissioner and the proprietor, with resultant inconvenience to both. A somewhat similar
situation has resulted in respect of the storekeeper-gaugers daily
and monthly reports of transactions at internal revenue bonded
warehouses and confusion has been created by efforts of correct
forms and records at all premises concerned.
3. It is important that reports be correct to the best of the
proprietor's knowledge and belief at the time of their execution,
and therefore the monthly report must reflect the correction of all
errors in daily transaction reports known at the time of its preparation. In the case of warehouse records, it is necessary that
they be sufficiently accurate to protect the revenue and to provide
reliable statistics. It is recognized that the tax gallons shown
on warehouse records are not, because of leakage and evaporation
losses, an exact statement of the quantity of spirits remaining in
the warehouse. Further, the preparation and submission by proprietors of numerous amended daily transaction reports and monthly
reports to correct minor errors may be onerous to both proprietors
and the Government. Accordingly, in lieu of requiring the preparation by distillers and warehouse proprietors of amended entry and withdrawal forms and monthly reports, the following alternative procedure will be acceptable:
(a) At the end of each month the proprietor of a distillery or an internal revenue bonded warehouse will
prepare a list of errors found by him during the
month in original tax gallon figures on completed forms covering the entry or removal of
distilled spirits, where the forms were prepared by proprietors. The list will provide:
(1) The identity of the form on which the
error occurred by showing the form
number and the serial number of the
form or, in the case of forms not
serially numbered, the date thereof.
(Date of withdrawal if form represents
a withdrawal from the proprietor's
premises, or date of deposit if form
represents a receipt of spirits).
(2) The identity of the error such as
"package serial number 134927 and
total tax gallons," or, if error is
only in addition of original tax gallons, "total tax gallons," the reported figure, the correct figure, and
the effect of the correction on the
book inventory of the warehouse or the
total production or withdrawals from
the distillery such as / (plus) 0.2
t.g. or (minus) 1.2 t.g.
(b) Distillers will show the totals of production or
withdrawals on their current monthly reports on
the basis of the daily reports adjusted for such
errors regardless of whether the form on which the
error occurred was for a prior or the current month.
Each entry on the report reflecting such adjustment
will be identified by an asterisk and a footnote as
having been adjusted pursuant to errors shown on the
(c) Proprietors of registered distilleries will deliver
the original of the list to the storekeeper-gauger
with their monthly report, Form 1598, delivered to
him at the end of the month as required by regulations in 26 CFR 220.756.
(d) Proprietors of fruit distilleries will submit the
original of the list to the assistant regional commissioner with Form 15, Part 3, rendered as required
by regulations in 26 CFR 221.772.
(e) Proprietors of internal revenue bonded warehouses
will deliver the original and one copy of the list
to the storekeeper-gauger at the close of the
month in which the errors are discovered.
(f) Copies of such lists will not be supplied nor will
notification be given by storekeeper-gaugers to
storekeeper-gaugers at other premises concerned.
The need for notification of consignee or consignor
proprietors of such errors will be a matter for
decision by the proprietors concerned. In any case,
correction at the premises concerned will be pursuant to the respective proprietor's separate listings of the errors.
4. It is believed that the procedure outlined will be advantageous both to the Internal Revenue Service and to proprietors.
Information 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 Tax Division