WHOLESALE LIQUOR DEALERS' RECORDS AND REPORTS
Wholesale dealers in liquors
and others concerned:
Purpose. This industry circular is to remind you of the record-keeping
requirements of 26 CFR Part 194 in respect of the showing of serial numbers
of cases of distilled spirits on your records of receipt and disposition.
Background. We have received information indicating that some wholesale
liquor dealers may have concluded that they may be relieved from the require-
ments of 26 CFR 194.225 and 194.226 in respect of entering the serial numbers
of cases on their records showing the receipt and disposition of distilled
spirits. This erroneous conclusion is apparently based on a misunderstanding
of 26 CFR 194.237, which contemplates that assistant regional commissioners
may specifically authorize wholesalers to omit such serial numbers from their
reports on Forms 52A and 52B.
Comment. The regulatory requirements for preparing and submitting reports
are separate from and in addition to the requirements for preparing and
maintaining records. It should be noted that Forms 52A and 52B are prescribed
report forms but that there are no prescribed forms for the records required
by 26 CFR 194.225 and 194.226.
Therefore, the fact that your assistant regional commissioner may have
authorized you to omit case serial numbers from your reports (Forms 52A and
52B) does not excuse you from entering such serial numbers in your records.
Inquiries. Inquiries about this circular should refer to its number and
be addressed to your assistant regional commissioner (alcohol and tobacco tax).
Dwight E. Avis
Directors Alcohol and Tobacco Tax Division