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I had a request from a local farm that wanted to buy bulk alcohol for tincture making purposes somewhere between 10-15 gallons. They have a state permit for purchasing bulk alcohol right now from a control state. However they don't have any federal permits and looking through the available permits I couldn't find one that they really fit in (wholesale was closest but they don't need to resell it). They have been buying from a big supplier for years and I want to help them out but I cant figure out how they can do it without a TIB permit from the feds. Does anyone have any experience with this? They are across state lines so I really want to make sure I am not doing anything illegal.

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I called TTB on this topic and they mainly care about the tax and reporting aspect. Record the 10-15 gals in Processing as packaged in bulk, put it in containers 1gal or larger, and pay your Fed excise tax on it.  State excise usually wouldn't apply, but you have to navigate two states' worth of laws, which may make the proposed transaction illegal in fact.  Might not be worth the risk/hassle for a small buy like that.

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