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Record keeping question for making whiskey one month and barreling it the next


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If I produce a malt whiskey in month 1 and barrel it in month 2,  how do I record this?

From the TTB monthly records, it appears as if I have to do the following:

Month 1 - Monthly report of Production - line 11 - entered into storage account, Part 3 - proof gallons deposited in tanks (under a created category "Malt" in column "a")

Month 1 - Monthly report of Storage - line 2 - deposited into bulk storage

Month 2 - Monthly report of Production, part 3 - proof gallons deposited into cooperage (under column (b) for new cooperage and under a created category "Malt" in column "a")

Month 2 - Monthly report of Storage - both line 11 (entered in storage account) and  Line 18 (transferred to production account)

Is this correct?  I am essentially transferring it back to production in order to barrel it, and then back to storage once it is barreled?  If so, it seems like there would be a line for "received from bulk storage" in the production report...

Thank you!


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No, it is not correct.  But kudo's on a good effort. And for recognizing that you should ask the question, because what you propose seems a bit weird.

First principals first - once you transfer spirits from the production account to the the storage account, you do not transfer them back to the production account. That is a "never-ever" rule, unless you are going to redistill them - and then only when you are starting over, not when you are taking neutral spirits and redisitlling to make gin or vodka, but that is another subject.  

That said, you have Month 1 down flawlessly.  To be sure we agree, you are correct to record the production in Month 1.  TTB insists that you record production - make a production gauge and prepare a gauge record - as soon as you finish the spirits run.  You are correct that, since it is going into storage, you record the transfer to the storage account at line 11.  You are again correct that you enter the same number into Part 3, creating the category malt.  By rule,. you must also designate the class and type of the product at the time you make the production gauge.  By rule, that can be whiskey designate, if you are going to put it into wood later.  But TTB should not quibble about the malt designation. And,finally, you are correct that you enter the deposit into the storage report at line 3.  

But that it is.  You are done with the transaction.  Do a happy dance.  There is no need to do anything more in month 2.

Note that the storage report records only "whiskey distilled at under 160 degrees."  Neither it, nor the front of the processing report, track what type of whiskey you a dealing with. Indeed, except for the statistical info on the back of the processing report, .the processing report lumps together all classes and types of spirits into a total of the proof gallons receive, bottled, removed, etc..

Why?  We do not ask why questions.  The only answer is, "It is because that's what TTB says." That is a "tums" remedy for avoiding heartburn.

The truth of the label claims, that the whiskey was produced in a manner that entitles it to the designation malt whiskey - distilled from 51% or more malt mash at under 160 and aged in new charred oak, etc., is captured in the records that you are required to keep, not the reports.  So, really, are the realities of your tax liabilities.  The reports are just summaries - TTB's version of the balance sheet and income statement found in financial accounting -  and while they provide TTB with an overview of your operations, provide hints of strange transactions when a number for one month seems out of character, and provide TTB with information required for its preparing  statistical reports that they must, by law, publish, they reports are the end of the audit trail, not a part of it.  The "meat" is in the records.   

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dhdunbar, can you explain this " That is a "never-ever" rule, unless you are going to redistill them - and then only when you are starting over, not when you are taking neutral spirits and redisitlling to make gin or vodka, but that is another subject." further, especially the last part?



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dhdunbar has it right. that is all you have to report, since what will move from non-barrel to barrel will still be in storage. however, there is a subtlety, since you could end up adjusting proof, and you will be re-gauging, and you could end up with a loss along the way. Then you would report that loss and the change in total stored alcohol in month 2, right? and, of course, your in-house records will be recording the container move and re-gauging as well.

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Sure, but only in a hurry, because the sky is falling today.  Redistillation of an existing spirit to make vodka or gin takes place in the production account.  The record is a production record - see Sec. 19.602  "Redistillation records. If a proprietor redistills spirits in the processing account (as in the production of gin or vodka by redistillation), the proprietor must prepare a record of the redistillation. The record must show the kind and quantity of the spirits entered into the distilling system and the kind and quantity of the spirits removed from the distilling system upon completion of the process."


I apologize for breaking my own rule that you do not say something unless you can cite the source.  I was in a hurry, as I am now.  Simply citing 19.602 tells the story.  Thank you for calling me on that.


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  • 5 months later...

Excellent explanation, dhdunbar. 

We have nearly the same scenario, but with a small twist.  Everything makes sense when the spirit type for the starting item and the ending item are the same, in this case both whiskey.  Start and end balances for the column are essentially the same minus any process yield.  

What do you do when the resulting item is not the same type?   I have an item in storage and I add flavorings or something to it so that it is no longer falls in the same column on the storage report.  If I try to complete this in storage, the column type consumed will be missing volume from the ending balance and I'll have extra volume for end balance of the produced column type.

About all I can think of is that this must be done is Processing where there are no column types.  Is this correct?

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You are correct.  Quickly, because I'm drowning in paper today, if you change class or type, you do not do that in storage.  Adding flavoring, which changes class and type,  takes place, as you summize,  in the processing account.  So you would transfer the whiskey as whiskey out of the storage account and into the processing account, where you would add the flavorings, according to an approved formula, of course.  If the flavorings have an alcohol content, then you need to record the number of proof gallons dumped into the product (line 4).  Ditto if the flavoring is wine.  You do not report any additions of flavoring that has no alcohol content (it does not change proof gallons, but you do need records of what you added to show that the product is properly labeled.).  

Note that you do not account for products on the front of processing report by class and type.  That is done on the reverse, part IV, where, in your example, you would enter whiskey into the account (column b of the appropriate row) and bottle it as a flavored product, which I would include at line 66, since they do not give a space for that.  No, I do not know why.  Note that the bottling entry is in wine gallons.   Again, why is because they say it is.  That's all.

That is the general answer.  For more specific info on specific products, write me and I'll get back to you to discuss how I can help.  

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