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Industry Circular

Number: 91-4

Date: April 1, 1991

Department of the Treasury Bureau of Alcohol, Tobacco and Firearms Washington, D.C. 20226


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Proprietors of Distilled Spirits Plants and Others Concerned.

Purpose: This circular is being issued to clarify the intent of 27 CFR 19.761.

Background: Section 19.761 allows for serially numbered invoices or shipping documents, signed or initialled by an agent or employee of the proprietor, to be used as the record of tax determination.

It has come to our attention that one series of numbers is being assigned among several distilled spirits plants (DSP) owned by the same proprietor. As each plant makes a tax-determined removal, the next available number in the series is assigned to the invoice or shipping document that identifies that removal. As a result, each plant's record of tax determination appears to be incomplete due to the gaps in its series of numbers. This method creates administrative difficulties for the Bureau.

Without obtaining files from each issuing plant, it is impossible to determine if the invoices or shipping documents are complete. Ready determination of the adequacy of records is the intent of serially numbered documents.

Conclusion: The regulatory requirements in 19.761 applies to each DSP registered with the Bureau. A separate series of numbers must be assigned to each registered DSP. The series must contain numbers that are sequential and uninterrupted. A number from the same series of sequential and uninterrupted numbers must appear on each record of tax determination.

Inquires: Inquires regarding this circular should refer to the above number and be addressed to the Director, Bureau of Alcohol, Tobacco and Firearms, Washington, DC 20226.

Stephen Higgins


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