Jedd Haas

I'm converting to Freedom Units and rounding. You had 317 gallons (1200 liters) at 10% ABV, which should yield 31.7 gallons of absolute alcohol, or 63.4 proof gallons. Your actual yield was 33 gallons (125 liters) at 50%, which is 33 proof gallons, or about half the expected yield. While you should have run until you were at 10% or less on the output, that doesn't account for half the yield. The most obvious answer is that your mash was not at 10%, but more like 5% or 6%. How did you determine it was at 10%?

Arranging and paying.

The agent did mention FAA (Federal Alcohol Act) as the relevant law but didn't mention a specific section.

Exactly. This is what the Fed Ex contract says. Also bear in mind that different laws may apply on a state-by-state basis for manufacturers vs. retailers. Type of alcohol also matters: in general, wine shipments are allowed in some states where spirits shipments are not. You may also be liable for excise tax payments on such shipments. Federal law may also come into play. There may be other (unknown) legal issues as well, all of which vary by state. Here is what a TTB agent told me: if you ship across state lines and you break the law, your permit is at risk. So there's that, in addition to 50 different sets of state laws and the Fed Ex contract. Bottom line for me is that I prefer to refer customers to our retail partners who ship and thus offload the risk.

1. Make sure you obtain any necessary permits, brand registrations, or fulfill any other regulatory requirements from the new state. 2. Standard shipping method: LTL freight. Look up "freight brokers" to get pricing. But really, your distributor should be arranging the shipment.

Fed Ex guidance: Once you have the alcohol agreement, don't ship to anyone other than a wholesaler or a competition. Fed Ex can, and will, conduct an audit of your shipments and ask you to explain them. Also, if you ship via Fed Ex without the alcohol agreement in place, they will deny any damage claims.

Oh yeah, I got that call too. Second time around: last time their celebrity host was James Earl Jones.

Also, TTB appears to be on top of this. The following notice has been added to the TTB web site: Congress has passed the Tax Cuts and Jobs Act of 2017, which makes extensive changes to the Internal Revenue Code of 1986, including provisions related to alcohol that are administered by TTB. The Tax Cuts and Jobs Act will become law when the President signs it. We are currently assessing the impact of these changes on TTB forms, regulations, and systems, and will issue guidance and information in the coming weeks.

The final bill has now been signed into law. You can google "pdf of tax bill" or similar to download a copy. Here is the portion on FET: SEC. 13807. REDUCED RATE OF EXCISE TAX ON CERTAIN DISTILLED SPIRITS. (a) IN GENERAL.—Section 5001 is amended by redesignating subsection (c) as subsection (d) and by inserting after subsection (b) the following new subsection: ‘‘(c) REDUCED RATE FOR 2018 AND 2019.— ‘‘(1) IN GENERAL.—In the case of a distilled spirits operation, the otherwise applicable tax rate under subsection (a)(1) shall be— ‘‘(A) $2.70 per proof gallon on the first 100,000 proof gallons of distilled spirits, and ‘‘(B) $13.34 per proof gallon on the first 22,130,000 of proof gallons of distilled spirits to which subparagraph (A) does not apply, which have been distilled or processed by such operation and removed during the calendar year for consumption or sale, or which have been imported by the importer into the United States during the calendar year. Here is the portion on "controlled groups." ‘‘(2) CONTROLLED GROUPS.— ‘‘(A) IN GENERAL.—In the case of a controlled group, the proof gallon quantities specified under subparagraphs (A) and (B) of paragraph (1) shall be applied to such group and apportioned among the members of such group in such manner as the Secretary or their delegate shall by regulations prescribe. ‘‘(B) DEFINITION.—For purposes of subparagraph (A), the term ‘controlled group’ shall have the meaning given such term by subsection (a) of section 1563, except that ‘more than 50 percent’ shall be substituted for ‘at least 80 percent’ each place it appears in such sub section. ‘‘(C) RULES FOR NON-CORPORATIONS.—Under regulations prescribed by the Secretary, principles similar to the principles of subparagraphs (A) and (B) shall be applied to a group under common control where one or more of the persons is not a corporation. ‘‘(D) SINGLE TAXPAYER.—Pursuant to rules issued by the Secretary, two or more entities (whether or not under common control) that produce distilled spirits marketed under a similar brand, license, franchise, or other arrangement shall be treated as a single taxpayer for purposes of the application of this subsection.

Exactly. Read the section on "controlled groups." I also haven't read it in great detail, but it appears that the purpose is to prevent precisely the kinds of schemes Joe theorized about. However, the idea of paying tax at the end of 2019 and moving product to unbonded storage may work.

A couple points for those who haven't been following this. 1. It's not official yet. 2. The FET reduction is only for 2018 and 2019. After that it reverts to the previous rate.

C'mon Joe, come clean. It's MGPI, isn't it.

They have a bunch of videos on youtube and they discuss their proofing practices in some of them. https://www.youtube.com/channel/UCOS_YyVxGQhUcavGyTSBrYQ/videos?disable_polymer=1

It's not the worst, but it's also not great. "Micro" in general strikes me as a lazy word. Easy to come up with, and not denoting much. Lots of other company names use "micro" as part of their name, notably Microsoft. With that name in mind, it has connotations of the computer industry, which seems at odds with the intended audience.

How about a picture or description of this system and the cost?

What was the name of the company?

Also, there doesn't appear to be a heat sink on that SSR, which means it is likely to self-destruct. OP, for your safety, I suggest you start over with someone who is qualified to build a control panel.

Plumbing supply house.

If you read 27 CFR, you'll see the word "barrel" is not used. Rather, TTB uses generic terms. So this would appear to be legal.

Ask your State agency. What do you think they will tell you?

I think you have a point, Silk City! I insert the cork slightly by hand, then use a lever action device I built to insert it all the way. Similar concept to the capper posted by Humulus. However, mine does not require lifting the bottle onto it. Just slide the bottle along the table, into position, pop it in with the lever, and done. Very fast and easy. In addition to manually loading the machine, the guy in the video also had to manually "space out" the bottles.

Looks like several things were done in a less than optimal way. Here is what you potentially should have done: 1. Had an agreement to transfer an initial percentage (say, 20%) to you. 2. Payment for remaining 80% held in escrow until all permits transferred to you. 3. Have yourself added as signing authority via Permits Online; have yourself registered for Formulas Online and Colas Online, and have your account for pay.gov set up. Until all of these steps are complete, do not proceed to step four. 4. Transfer remaining 80% to you. 5. File Change in Control via Permits Online. Do not send paper forms! 6. Transfer or re-file for all local and state permits. 7. After all permits are in your name, release remaining payment from escrow. 8. Probably have a consulting agreement with the former owners to ensure you're filing your monthly reports correctly. As to what you can do now? Start calling the TTB. Find out if they even have your paperwork. You may be in for a long wait just to get someone on the phone. Maybe re-file what you can in Permits Online, along with an explanation for the duplicate filing.

Yes. Yes, Line 28 should equal line 9. Line 29 is presumably if you receive bottled inventory from some other source. Note that per the footnote on line 32, you can't receive bottled product in bond. In general, you probably won't withdraw bulk spirits on a tax determined basis. So line 13 will likely remain unused in general use. Line 33 is for bottled product, or, in the second column, for "packaged" product, meaning drums, barrels, or other containers larger than standard bottle sizes. A lot of the lines on these reports seem to be for esoteric situations and most will be left blank in general use. Note that even though the TTB has thought of all of these situations, they still leave a few blank lines (21-23, 41-43) where you can add in transactions that they didn't include.

I had some correspondence with Greg from STM, the eDrometer manufacturer, and invited him to participate in this thread.

What is the price range for these units?