Proprietors of distilled spirits plants and others
Purpose. Some industry members have inquired
whether physical inventories are required in support
of tentative operational loss claims and what adjust-
ments to records are intended by Revenue Ruling 68-219.
A physical inventory is required by 27 CFR 201.492
for all claims for operational losses, whether tenta-
tive or final. This section requires an inventory for
any period for which a claim is submitted under 27 CFR
201.45(d). The latter section applies to any claim
filed for operational loss.
We are presently amending the regulations to
clarify the fact that a physical inventory is required
to support any such claim.
On the question of adjustment to records,
inventories taken for purpose of operational loss
claims are not synonymous with the controlled stock
inventories, which are taken for a different purpose
and which include finished goods. However, whenever
physical inventories of bulk goods are taken for
operational loss claims the resultant adjustments must
be posted to individual transaction records and
summaries, and the overall gains or losses from the
bulk controlled stock (but not noncontrolled stock)
must additionally be recorded pursuant to 27 CFR
Inquiries. Inquiries concerning this circular
should refer to its number and be addressed to your
regional regulatory administrator.