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dhdunbar

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    Eclectic - from square dancing to Miles Davis; browsing the library for books of interest - Tony Hillerman crime novels to popular books on quantum physics. Simply sitting. Cooking dinner when someone else will wash the dishes. Walking the dog. Poetry and epistemology. Writing.

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  1. Transfer Spirits FROM BW -to- DSP?

    A winery may return, to a DSP, wine spirits that it obtained, from a DSP, for use in wine production. The DSP may receive them for any lawful use. To understand who, what, where, and how, forget analysis and guesses from operating report forms. To understand the rules, you must look to the regulations. TTB employees who give answers without consulting the regulations can lead you astray. In this case, working through the regulations is not an easy chore. Let’s do it anyway, because it is chock full of learning points: When the distillery ships the spirits to the winery, the spirits remain in bond. “In bond” is defined to include “spirits withdrawn without payment of tax under 26 U.S.C. 5214, and with respect to which relief from liability has not occurred under 26 U.S.C. 5005(e)(2) [§19.1].” Shipping spirits to a winery for the winery to use in wine production is a withdrawal under §5214. Take note of the term “withdraw without payment of tax.” For accounting purposes, a withdrawal without payment of tax is not a “transfer in bond.” The rules distinguish between the two. The withdrawal to a winery is treated as a withdrawal without payment of tax tax for use in wine production [§19.418(a)(6)]. You should report the transaction as a “withdrawal without payment of tax for use in wine production” on the account from which you withdrew them. The forms have a line for this. Do not report it as a transfer in bond. To be clear, the sprits are “in bond,” but the transfer is not a “transfer in bond,” it is a “withdrawal without payment of tax.” There is no natural law at work here; these are arbitrary rules, but they are important because they make for consistent recording and allow TTB to make different rules for returns and relief from the tax liability. For accounting purposes, they are no more arbitrary than the distinctions accountants make between, say, long-term and short-term liabilities. For rules, they are no more arbitrary than the different speed limits one sees for cars and trucks. To handle the accounting correctly, and to follow the rules, you must know what the terms mean and how to classify the transactions. With definition out of the way, Section 19.454(i) applies to returns of spirits from a winery to a DSP. It provides, “Wine spirits withdrawn without payment of tax for use in wine production can be returned to any DSP [note, not just the DSP from which they were withdrawn] for any lawful purpose, subject to two conditions. · The DSP proprietor must obtain approval as provided in §19.403. That is the section that requires an application to TTB to receive a transfer in bond. Here TTB allows the return of spirits withdrawn without payment of tax to piggyback on the transfer in bond application, even though the transfer is not treated as a transfer in bond for accounting purposes. · The winery must follow the wine regulation. Section 24.226 provides, in pertinent part, “If spirits are to be transferred to a distilled spirits plant or to bonded wine premises, the proprietor shall use the transfer record and procedures prescribed by §19.405.” That section describes the transfer document for transfers in bond. Again, although it is not a transfer in bond, TTB piggybacks, presumably as a matter of convenience, on the transfer in bond provisions. Mixing the documentation for returns of spirits withdrawn for use in wine production with the documentation required for transfers in bond can lead to confusion. But be clear. Neither the shipment to the winery nor the return from the winery are treated as transfers in bond. With that in mind, here are the rules: The shipping winery prepares the transfer record required by §19.405. Yes, this is a transfer in bond record. The receiving DSP must follow the rules in §19.407. These are lengthy and I will not repeat them here. Receipt involves, among other things, gauging the spirits received, entering certain information to the transfer record, reporting unusual loses, and, of course, making entries to the appropriate DSP record. The regulations make specific provision returning the spirits to the production account and the processing account. They do not make specific provision for returning them to the storage account, but I see no harm in doing so, since they may be returned for any lawful purpose, which would include storage. Section Sec. 19.315(a)(3) provides the rules for redistillation in the production account. It provides, “A proprietor may receive and redistill spirits have been withdrawn without payment of tax and returned to bond under subpart T of this part (Subpart T is an error, it should be subpart Q). Note, that if, for any reason, you want to redistill the spirits, you must first have an approved formula. That requirement is well hidden in the §19.77(b), which requires statements of production procedure, and is easily overlooked. It provides, “If the applicant intends to redistill spirits in the production account, the applicant must submit and receive approval for such redistillation on form TTB F 5110.38, Formula for Distilled Spirits under the Federal Alcohol Administration Act.) Sec. 19.342 (c) provides that a DSP may “receive spirits into the processing account that are returned to bond under the provisions of 26 U.S.C. 5215. The rules for receiving spirits into the storage account do not include any provision that specifically states that you can receive, in the storage account, spirits withdrawn without payment of tax. Here, I must break my “read the regulations rule.” I think the omission is a glitch, to use a nontechnical word. Line 4 of the monthly report of storage operations captures returns of bulk spirits into the storage account. In a roll-over form that explains the entries to be made in on each line, TTB gives an example. You would use line 4, they say, to record the return of bulk spirits that were shipped to, but refused by, the consignee. Since you may return, to your DSP, for any lawful purpose, spirits withdrawn, without payment of tax, to a winery, for use in wine production, returning such spirits for storage is appropriate. That is a long string of prepositional phrases for which I apologize. Line 4 is a convenient place to record the transfer. That is short and to the point, even if I cannot find a direct reference to this in the regulations.
  2. DSP Site Access Requirements?

    Re: TTB requirements - TTb will never see the road until after the application is approved, so the question may be moot. However, I see nothing that would allow TTB to deny the application based on the fact that in bad weather they have to walk a half mile from the parking area rather than 50 feet. I see no general requirement that would require that you plow snow, for instance, or fill potholes, or otherwise ensure that TTB can drive to within a certain distance of the door. When TTB approves variances, etc., the question is whether approval would "hinder the effective administration of this part." I'm tempted to argue that it is important that TTB uses this provision, because it shows that it is concerned with, and considered, hindrances when it wrote the regulations. Thus, since it considers hindrances, and did not include this in the provision re: construction, etc., hindrance or in convenience should not be considered in deciding whether to approve or not.. Then I think about putting a DSP in a treehouse. Hmm. I think TTB assumes that, for your own purposes, you must provide reasonable commercial access. I think it assumes that such access will suffice. I also think that if the local development department and fire marshal approve, TTB has no grounds to deny. But not in a treehouse, please.
  3. Loss of abv while carbon treating

    Let's agree to this - the rule is you make the bottling gauge after the cut to bottling proof, i.e., when the spirits are ready to go into the bottle with no further changes to them, i.e., everything but bottling is completed. If you cut to bottling proof before filtration, then any loss of proof after filtration, is going to bring you out of compliance, because the spirits in the bottling tank must be at bottling proof. Because there is no tolerance, you are going to have to add spirits to the filtered product to get back to the bottling proof, then regauge. The tolerance is only for evaporation loss in the bottling process. That is a wonky distinction, because I do not think TTB would tumble to the wonky problem, if the bottled spirits were within tolerance, but it is nevertheless the requirement. The easy solution is to reduce after filtration, but TTB does not prohibit adding spirits to bring filtered spirits back up to bottling proof.
  4. Processing form Line 13 & 29

    Yes, the rollover form is on TTB's website, but TTB has made the rollover form damned hard to find. Go to TTB.gov and scroll ti the bottom of the page. In the Resources column click on Forms. Scroll down to Tutorials and Helpful Hints, Click on Form 5110.28. The form doesn't appear. A page with various links to hints, etc, appears. There is no direct link to the rollover form here that I can find, so continue to FAQ. There is a link here, Click to Access Firm. Click that link. You get the rollover form, not a blank form. I can't get to it any other way, but there may be a shortcut I have not found. The forms are helpful, but not complete. I find three areas where I think they do not adequately explain what should appear on the form. Without going long, these are: The return to bond of bottled spirits as I explained above. The rollover states only that you cannot receive packaged spirits in bond from another DSP. It does not explain receipt for rebottling or reconditioning or how that is handled differently than receipts for relabeling. The distinction between redistillation that takes place after transfer if spirits for redistillation in the production account and the redistillation that takes place in the processing account. See Sections 19.77, 19.314, and 19.602. On hand end of month figures and how they differ in months when you take quarterly inventories of bulk spirits and semiannual inventories of packed spirits. In non-inventory months, they are balancing figures needed to make the total to account for equal to the total accounted for. In inventory months they are the actual quantities, with differences between the to account for and accounted for figures accounted for as gains and losse. So yes, the rollover is generally helpful and I recommend that you look at it, but it is not complete and it does not always explain how TTB is using the terms you find there.
  5. Processing form Line 13 & 29

    You have a basic grasp. Part 1 - bulk; part 2 - bottled (packaged is for industrial spirits). The spirits normally move from bulk to packaged. Movement between the bulk and bottled accounts is by balancing entries that decrease the total to account for in one account and increase the total to account for in another. Also, remember that the total you must account for (line 8 and 31, for bulk and bottled respectively, must agree with the total you account for (lines 26 and 47 respectively). You can return taxpaid bottled spirits to bond, but only for certain stated purposes, e.g.. reconditioning, rebottling (see 19.452, which lists a lot of requirements and conditions if you do that). That is where you would receive bottled goods at line 29. To answer your question, no, line 29 is not the same as line 2. Always keep your accounting for bulk and bottled goods separate and remember that anytime you move between the two, you have balancing entries taking them out of one and putting them into the other (the equality of lines 9 and 28 and lines 6 and 40) . Note that spirits received on the bonded premises for relabelling only (19.453) are not returned to bond. A clarification re the footnote - Tax paid or determined spirits are not in bond, so, when they land in your DSP, you are not receiving them in bond. You are returning them to bond. When you return them to bond (rebottling/reconditioning, but not relabeling) you get into the need to file a claim, etc. and pay taxes all over upon removal. This is not the case with relabelling because you will not have done anything to affect the taxable quantity in the container. If you understand the impact of what you do with the spirits once they are on bonded premises, then you can see why relabeling is treated differently. Now I've done my good deed for the day :-).
  6. Loss of abv while carbon treating

    Good call - insist on citations. From me, from TTB, from everyone. When it comes to regulation, advice that begins, "I think ..." should be suspect. Sometimes we have to figure out what is required by "reading between the lines," but these regulations were updated in 2011 and the basic requirements go back to 1980. TTB has had a lot of time to iron out the wrinkles of ambiguities. Sec. 19.353 Bottling tank gauge - When a distilled spirits product is to be bottled or packaged, the proprietor must gauge the product after any filtering, reduction, or other treatment, and before bottling or packaging begins. The gauge must be made at labeling or package marking proof, and the details of the gauge must be entered on the bottling and packaging record required in Sec. 19.599.
  7. Reuse Glass Bottles?

    I'll repeat from my former post. Distillers can relabel. If a distiller relabels and the product does not meet the standards of identity, then there is a problem. Of the distiller relabels with a label for which he does not have label approval, then there is a problem. But otherwise, the issue of removing labels applies only to wholesalers and retailers, who do not bottle spirits. Now, since wholesalers and retailers do not bottle spirits, any spirits they have come in a bottle filled and labeled by a DSP, or it damned well better come in a bottle filled by a DSP. Since the spirits are already in a bottle with a proper label, there should be no reason to put them into a n empty bottle with the same label. To what end? The only reason to pour one bottle into another (well, I guess a retailer could argue consolidation, but that sounds sort of hollow) is to put less expensive products into bottles purporting to be expensive product., soi that they can the public into paying premium prices for goods not marketed as premium. That is why you have emphasis on relabelling. And refilling. I can't quite refrain from asking a question - if the consumer can't tell the difference ... okay. I'll refrain.
  8. Can we ship bottles to customers?

    we've visited this in detail before. hedgebird provided a link to the website of the National conference of State Legislatures, which includes a complete list of all state laws (http://www.ncsl.org/research/financial-services-and-commerce/direct-shipment-of-alcohol-state-statutes.aspx.) I've cited TTB's positon (https://ttb.gov/rulings/2000-1.htm and https://ttb.gov/publications/direct_shipping.shtml) fssmatt cited Fed Ex rules (http://www.fedex.com/us/freight/rulestariff/prohibited_articles.html). So you've got the state's public statements, TTB's public statements, and Fed Ex's public statements. I'll tell you now, no alcohol may be shipped via the US Post Office. TTB and TTB alone has that privilege. There is nothing new to report. I've not put it this bluntly before, but "What is your tolerance for risk?"
  9. That is correct. You want to deal with someone who can supply you with both beverage alcohol and a basic permit number. That is not the DSP number. The DSP number, in the format DSP-HI-20015 (I can dream about being in Hawaii, right) is not the basic permit number. The basic permit number will be of the form HI-S-20163. You can check TTB's website for a list of persons who hold basic permits for beverage alcohol. I have seen some industrial suppliers insist that they can sell to beverage producers. TTB says no. To get around the arguments that follow from citation of regulation, here is the wording of the second instruction on the Form 5100.16 (paper format): "In-bond shipments must be authorized transfers. For example, industrial (nonbeverage) spirits may not be transferred to a plant whose permitted operations are solely non-industrial (beverage)." That is definitive to my mind. It seems not to be definitive to some suppliers of bulk spirits. The supplier may insist it don't need no stinking basic permit, but the supplier does need a stinking basic permit to produce beverage alcohol. And it may not ship industrial alcohol to you unless you are qualified to receive industrial alcohol.
  10. Distillery Location

    Sothlander Oh what tangled webs we weave. I agree with you. At its core, my arguments rest on the observation that a yard does not necessarily extend to the limits of the piece of property on which it sits. I also agree that neither the statute or the regulation mention the phrase "tract of land." Indeed, my argument, on behalf of clients, is that TTB should approve the application, in their case, because the protection afforded to the residence does not extend to the far reaches of the property, only the the "yard." In legal terms, I argue that the the DSP, or perhaps more importantly, that the land surrounding the DSP, is not so intimately tied (that is the phrase used by the Supreme Court) to the residence that the umbrella of protection (the court's wording again) afforded to the residence extends to the DSP. My interpretation is your interpretation. We agree. However, there is a problem with the notion of a meaning seeming straightforward to you and I. TTB gets to decide what the statute means. The courts give it wide deference to do so. Einstein said that common sense reflects the prejudices we have at age 18. TTB has held certain prejudices and as a result, its notion of of what constitutes the yard, for the purpose of the statute, may be different than yours or mine. For example, in the last "Expo," which TTB presented in 2009, when it still had funds to hold such events, there was a PowerPoint slide stating: “Connected with any Dwelling House” • Examples: – Land back behind the wood lot – An outbuilding next to a farm residence – An attached or detached garage on residential properly – A commercial building with attached apartments or condominiums The reference to "land behind the wood lot expresses" a prejudice that TTB, or at least its presenter, had in 2009. TTB's common sense said, as late as 2009, that the prohibition extends to the land behind the wood lot. I do not attend ADI conferences, but two years ago, a former TTB employee, who now consults for an attorney firm, witnessed a TTB specialist still arguing that the specialist would never approve an application where the DSP was located on property which also had a residence, and this in spite of the fact that such approvals had been granted. TTB's Regulations and Rulings Branch has stated, in a private letter ruling, that "TTB applies these provisions on a case-by-case basis in circumstances where a person seeks to establish a DSP on property that includes a residence in a separate structure. When applying these provisions, TTB considers the distance between the residence and the DSP, whether any physical barriers separate the residence and the DSP, and any other relevant factors. Of course, since TTB no longer visits the site prior to deciding whether to issue a permit, failure to disclose that the DSP is located 20 feet from a residence could result in TTB's approving the application. A TTB employee visiting the site might even ignore the close proximity of the residence. But TTB could come to object. I advise people to act according to their own comfort with risk, since the law doesn't say that TTB will not approve an application where the DSP is too intimately tied to a residence. It says that the person making the application may not establish the DSP in a residence, etc... The onus is on the applicant to comply and the disclosure of collocation is relevant and perhaps material information. TTB gets to decide whether its material.
  11. Distillery Location

    Sothlander Oh what tangled webs we weave. I agree with you. At its core, my arguments rest on the observation that a yard does not necessarily extend to the limits of the piece of property on which it sits. I also agree that neither the statute or the regulation mention the phrase "tract of land." Indeed, my argument, on behalf of clients, is that TTB should approve the application, in their case, because the protection afforded to the residence does not extend to the far reaches of the property, only the the "yard." In legal terms, I argue that the the DSP, or perhaps more importantly, that the land surrounding the DSP, is not so intimately tied (that is the phrase used by the Supreme Court) to the residence that the umbrella of protection (the court's wording again) afforded to the residence extends to the DSP. My interpretation is your interpretation. We agree. However, there is a problem with the notion of a meaning seeming straightforward to you and I. TTB gets to decide what the statute means. The courts give it wide deference to do so. Einstein said that common sense reflects the prejudices we have at age 18. TTB has held certain prejudices and as a result, its notion of of what constitutes the yard, for the purpose of the statute, may be different than yours or mine. For example, in the last "Expo," which TTB presented in 2009, when it still had funds to hold such events, there was a PowerPoint slide stating: “Connected with any Dwelling House” • Examples: – Land back behind the wood lot – An outbuilding next to a farm residence – An attached or detached garage on residential properly – A commercial building with attached apartments or condominiums The reference to "land behind the wood lot expresses" a prejudice that TTB, or at least its presenter, had in 2009. TTB's common sense said, as late as 2009, that the prohibition extends to the land behind the wood lot. I do not attend ADI conferences, but two years ago, a former TTB employee, who now consults for an attorney firm, witnessed a TTB specialist still arguing that the specialist would never approve an application where the DSP was located on property which also had a residence, and this in spite of the fact that such approvals had been granted. TTB's Regulations and Rulings Branch has stated, in a private letter ruling, that "TTB applies these provisions on a case-by-case basis in circumstances where a person seeks to establish a DSP on property that includes a residence in a separate structure. When applying these provisions, TTB considers the distance between the residence and the DSP, whether any physical barriers separate the residence and the DSP, and any other relevant factors. Of course, since TTB no longer visits the site prior to deciding whether to issue a permit, failure to disclose that the DSP is located 20 feet from a residence could result in TTB's approving the application. A TTB employee visiting the site might even ignore the close proximity of the residence. But TTB could come to object. I advise people to act according to their own comfort with risk, since the law doesn't say that TTB will not approve an application where the DSP is too intimately tied to a residence. It says that the person making the application may not establish the DSP in a residence, etc... The onus is on the applicant to comply and the disclosure of collocation is relevant and perhaps material information. TTB gets to decide whether its material.
  12. Distillery Location

    This is always the simplest way to go, from the TTB angle. I would not necessarily suggest that he sell the land to the legal entity wanting to open the distillery. John's attorney might advise him to sell it to a separate entity, which will then lease the premises to the operating entity, to minimize the exposure of the property and improvements to loss in a suit brought against the operating entity for an alleged transgression by either the entity or its agent. Those are decisions best left to the attorney and accounts and made for business reasons, not for the sake of the TTB application. But certainly, dividing the property is an option where division or other property line adjustments are feasible under zoning and covenants, if any. That is not always possible. For example, our house sits on 5.84 acres. The residence, yard, and outbuilding occupy, maybe, 1.5 acres, so I could just carve off four acres and build my distillery on that land. But I can't. Under current zoning, my 5.84 acre parcel should not exist. With a few others, we are four to six acre residential islands in what is otherwise zoned as 20 acre agricultural use. Further, those of us who have built on the islands are prohibited, by covenant from dividing the property into smaller parcels. But indyspirits is correct. If John's attorney and account and zoning and covenants and the associated costs allow carving off 5 acres (or whatever is needed) for the distillery, that is a feasible and far simpler route. When the residence is not located on the same tract of land, it could sit three feet from the distillery and not present a problem under 19.52.
  13. Distillery Location

    Yes, no and maybe. I hate giving that sort of answer, but sometimes it is necessary. When I get specific questions about specific circumstances, I am reluctant to answer without pursuing details. Make that, I won't answer without pursuing details. When I get approval for collocation, TTB states only that they make their decision on a case by case basis. They do not provide go-by guidelines. Where they don't, I cannot do so either. They simply state that they have concluded that, in this instance, they would not recommend disapproval based solely on the location, since they have concluded that the residence is not connected to the DSP, as the term "connected" is used in 19.52 and the underlying statute. They give the "would not recommend" answer because the person answering is not the deciding official on whether or not to approve and they do not want to appear to usurp that person's authority. When I get to talk with someone about the specific facts, I ask a lot of questions and then suggest that, based on my experience, it is probable that TTB would allow or probable that it would not allow the person to have a DSP at the proposed location. Your facts do not allow me to reach either conclusion. TTB does not express it this way, but the issue appears to be whether the proposed DSP would come within the curtilage of the residence. Curtilage is a legal concept (I am not an attorney) with common law roots that got embedded into the constitution in the 4th amendment. Curtilage is a reasonable expectation of privacy at a location within a yard, outbuilding, etc, associated with a residence, which the Supreme Court says results from a number of factors, including, but not limited to, the proximity of the residence and the proposed DSP. Without more facts, I can't answer whether TTB might concludee that the curtilage of the above residences would likely extend to the DSP [and in any case, I'm not in the business of giving legal advice; I just report on the results of my experience :-)]), or what mitigation TTB might expect, in terms of shared vs. separate entrances, fences,lease terms, etc. Confirmation bias being what it is, even with more facts, I don't want to tempt people to extrapolating from what I think TTB might say about one case to what it might say in another. The best I can do here is state that, in 19.52, TTB has posted a no trespassing sign, but that TTB will also allow trespassing, with its permission, in some but not all cases, and that I know that it does so because X times in the past I've gotten TTB to allow it after openly telling them all the facts.
  14. Distillery Location

    I will say something that is obvious in everything said above. I assist with federal regulations, but I always tell clients take care of local issues first. TTB does not just assume that you are zoned properly; whether or not you are zoned properly is not a matter of official concern to them. They do not care if there is a childcare center in an adjoining unit, with no proper fire barriers. The official attitude is "Let the kids perish." They don't care if you want to locate within 500 feet of a church and that doing so might upset the parishioners, who according to blue laws such as that, must be more tempted to demon rum than those who attend church more than 500 feet away. The official position is "So be it; let those sinners descend into depravity." Unless the laws of the state completely forbid anyone from engaging in the business you propose, i.e., the laws make it illegal to operate a distilled spirits plant, for example, in that state under any circumstances, TTB has no legal basis for denying federal registration and permits on the grounds that your project would somehow offend local or state ordinances, That TTB is officially callous is a good thing. Would we really want a situation in which federal approval depended on a promise not to speed when making deliveries? Official callousness is obviously, and properly, not true of the local fire marshall and others who enforce local codes. No doubt, officious objections can cause real problems for you when there is no real problem with what you propose, but DSP's can also create real problems with which state and local codes must deal. Generally, my advice is, "Do not worry about TTB. We can work around most potential objections." There is a brewery located in the same warehouse space? Okay, we'll put up a chain link fence and make sure a door to the proposed DSP opens into a public area, etc. From the list someone posted above (and it is a good list, lifted straight from the regulations, which in turn lift it straight from the stature), the stumbling block can be a residence on the same tract of land. However, that is not hopeless. If you live in an area that will allow you to have a DSP on the residential property, and want to put a DSP in an outbuilding, do not ignore TTB in the early planning states. Otherwise, think local first.
  15. Conversations go in weird ways. GNS, by which I assume you mean grain neutral spirits, is GNS, whether you buy it from a supplier or distill it yourself. You must consider two things. First, the use to which you put neutral spirit determines if the spirits are industrial or nonindustrial (beverage) alcohol. Second, beverage spirits may only be distilled, warehoused, and processed by persons who hold basic permits as producers or processors of beverage spirits. As a result, you may not buy GNS for use in beverage products if the alcohol was not distilled by someone who is authorized to disitll beverage alcohol, .i.e, someone who holds a basic permit in addition to the plant registration. If the neutral spirits were produced as beverage alcohol, whether you buy the neutral spirits or distill them yourself is of no consequence to your use of them to manufacture beverage alcohol products. However, it will affect label statements, which is probably why you want to redistill it rather than simply using charcoal filtration. KKBodine is correct. You will need a special "permit" to receive spirits in bond. You make application to TTB to receive spirits from a specific supplier and TTB approves the receipt of spirits from that supplier. Four suppliers? Four separate applications and four separate approvals. But the permit is good for repeated transfers. You may apply for transfers in bond when you apply to register the DSP and for your basic permit. You do not have to wait until you have your permit, at least if you use permits on line and do use permits on line for about 32 reasons on which I do not wish to elaborate here. TTB will not authorize the transfer until you have a DSP. I don't have time to cite the sources, but don't let TTB get away with statements like, "{You may need ..." Tell them to cite a source that you can read for yourself. I'm busy now, or I would do that. You should not rely on what I say, or anyone else says, unless I or they or TTB can tell you how they reach the conclusion.
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