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If I buy a barrel from anyone for blending do we have to bottle it before we can get it to the factory? I also think the vendor has to pay tax on it, and i would pay tax on it once it left.

also to bottle a barrel that was going to be used for blending seems odd.

any incite?

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Curtis,

You can buy bulk spirits in bond if you are a licensed dsp or rectifier. So that means they ship you barrels of untaxed spirit under your withdrawal bond. Then you blend it, bottle it and pay the tax.

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What if a factory goes dark. How do you buy the old stock?

http://www.ttb.gov/spirits/forms.shtml

TTB F 5100.16

If it can be "sold", there would need to be a "legal" entity to engage with for the transfer/sale. If you were to put it in glass, there would need to be a TTB approved label to "sell" or "transfer" the product to you. If it fell onto your truck, you would risk losing your license and may lose the ability to retain the reputation of "a good operator" with Federal and/or State bureaucracy. If you choose not to pay your excise tax, you risk confinement with some of the more questionable inhabitants of the planet.

opinion of a tired old Boy Scout.....

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Not an answer, but, this is why the TTB should continue its "Expo" education seminars. I'm glad I attended when they did in Ohio. I believe there are several questions built into the one asked by Curtis. This is a well traveled path in this industry and there are no "What if's" in the eyes of being tax compliant. Purchasing Bulk spirit is a huge part of the business. Get familiar with the TTB BAM and its "transfer in bond" aspects.

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  • 2 months later...

Since this is from a few months back, you may have already found out that it's covered in 27 CFR. But in case you haven't; and for the benefit of everyone else who may be wondering about transfers in bond, you need form f510016.pdf which is called:

APPLICATION FOR TRANSFER OF SPIRITS AND/OR DENATURED SPIRITS IN BOND (See instructions on the back of this form. See 27 CFR 19.505-510)

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