Form 5110.11 usage

[Thatch]

The person who was filing our reports has left the company.  As I am sorting through things I find that he has been filing storage reports as other than zero.  When reading the TTB web site it states: 

"Generally, storage is when you hold bulk quantities of product without specific plans for further processing". 

In our operation we do not hold bulk spirits.  What is the proper way to correct this?  Do I need to file amended reports or just start reporting zero?

The web site also says: 

 "you may obtain approval from TTB to defer filing of storage reports until you begin storing spirits."

How do I file for this deferment?

 

 

[Silk City Distillers]

Given that "bulk" is considered one wine gallon and larger, we've always filled out storage reports.  Obviously everything in a barrel is going to be reflected on the storage report.  If you buy or make neutral in bulk, and draw down from that volume occasionally (small gin run for example), that's going to exist on the storage report.

Generally, for unaged spirits, our production cycle has it starting and finishing within the month.  So out of the production report, they move directly into the processing report, and don't check in and out of the storage report.

For example:  distilling vodka (production) -> transfer to processing (processing and bottling).  If it sits in the bottling tank for a few days before the bottling run - I don't reflect it on the storage report.  Occasionally, bottling gets delayed, and we'll run over the month-end.  Slap my hand, but we've still never shown this on the storage report.

[Thatch]

2 minutes ago, Silk City Distillers said:

Generally, for unaged spirits, our production cycle has it starting and finishing within the month.  So out of the production report, they move directly into the processing report, and don't check in and out of the storage report.

For example:  distilling vodka (production) -> transfer to processing (processing and bottling).  If it sits in the bottling tank for a few days before the bottling run - I don't reflect it on the storage report.  Occasionally, bottling gets delayed, and we'll run over the month-end.  Slap my hand, but we've still never shown this on the storage report.

Thanks Silk,

Our process is similar to the portion of your text I have quoted.  How do I correct the incorrect reports??? We have NEVER had storage and we will not likely have storage in the future.  

[Silk City Distillers]

Not sure I'm following exactly.

Are you saying that for your storage report, under the Vodka column.  You show an amount under the "2. Deposited in Bulk Storage" and then the exact same amount under "17. Transferred to Processing Account"?  Maybe occasionally (month-end) - you have on-hand amounts reflected?

If so, I'd say just change your process going forward, why bother going back and amending?

Maybe @dhdunbar can weigh in on whether or not it's serious enough to go back and amend previously submitted reports.  To me it seems inconsequential that your clear spirits reporting took a pit stop over on the production report.  The numbers are accurate, and it's certainly not impacting excise tax calculations.  Technically it's a valid reporting "path".  The only real offense is overcomplicating the storage report.  Is it worth opening a can of worms to resubmit?

I wouldn't stop reporting on the storage report after the change, I'd just submit with a few token zeros.

[Thatch]

Answers in BLUE 

14 minutes ago, Silk City Distillers said:

Are you saying that for your storage report, under the Vodka column.  You show an amount under the "2. Deposited in Bulk Storage" and then the exact same amount under "17. Transferred to Processing Account"?  Maybe occasionally (month-end) - you have on-hand amounts reflected?  YES

If so, I'd say just change your process going forward, why bother going back and amending?  That's the question.

Maybe @dhdunbar can weigh in on whether or not it's serious enough to go back and amend previously submitted reports.  To me it seems inconsequential that your clear spirits reporting took a pit stop over on the production report.  The numbers are accurate, and it's certainly not impacting excise tax calculations.  Technically it's a valid reporting "path".  The only real offense is overcomplicating the storage report.  Is it worth opening a can of worms to resubmit?  I hope not, hopefully Dave will chime in.

I wouldn't stop reporting on the storage report after the change, I'd just submit with a few token zeros.  I won't stop until they say I can stop.  Supposedly there is a deferment available.

 

[JNorris]

Thatch - If you still need some help, shoot me an email and I will try to help you with your reports.  No sales pitch, just a little assistance.