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Industry Circular

Number: 69-14

Date: June 6, 1969

Department of the Treasury

Internal Revenue Service

Alcohol, Tobacco, and Firearms Division

Washington, D.C. 20224

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REPORTING ON FORM 2733 OF WHISKEY EXEMPT FROM RECTIFICATION TAX

Proprietors of distilled spirits plants and others concerned:

Since the issuance of regulations providing in 26 CFR 201.444a for the exemptions contemplated under section 5025(k), I.R.C., some confusion has arisen with respect to the reporting on Form 2733, in Part III, of whiskey exempt from rectification tax under 26 CFR 201.444a and whiskey exempt from rectification tax under the provisions of 26 CFR 201.444.

Whiskey mingled under the provisions of 26 CFR 201.444 is generally recognized in industry as a rectified product although exempt from tax. On the other hand, whiskey mingled or treated under 26 CFR 201.444a, although correctly a rectified product, conforms more closely to the trade's understanding of an unrectified product. Accordingly, it is requested that such products be reported in Part III of Form 2733, as follows:

Report domestic whiskey, rectified and exempt from tax under 26 CFR 201.444a, in column (h) at line 5. Report domestic whiskey, rectified and exempt from tax under 26 CFR 201.444, in column (i) at line 2. Report imported whiskey, rectified and exempt from tax under 26 CFR 201.444a, in column (g) at line 5 when dumped and in column (h) line 5 when bottled.

Inquiries concerning this circular should refer to its number and be addressed to your Assistant Regional Commissioner, Alcohol, Tobacco and Firearms.

Ralph Alkire

Ralph H. Alkire, Acting Director

Alcohol, Tobacco and Firearms Division

 
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