Rev. Rul. 54-188

Permission is requested by the proprietor of an internal revenue bonded warehouse to make application for domestic bottled in bond strip stamps in quantities required for each bottling dump immediately prior to the actual bottling of the spirits rather than estimating the number of stamps of a specified size or sizes when filing application on Form 1515 for permission to bottle.

The requirements of section 185.974 of Regulations 10, if strictly construed, result in a hardship in cases where it is found that the predetermined denomination of stamps according to bottle sizes is changed after the order for stamps is placed. Such hardship could be avoided if the stamps were requested and obtained pursuant to Form 1515 after the spirits have been dumped and prior to the actual bottling of the spirits contained in the bottling tanks.

Application on Form 1515 must be filed for each lot of spirits to be bottled in bond and Regulations 10 requires that such spirits be bottled expeditiously. Therefore, it is not contemplated by the regulations that the spirits will be held in bottling tanks for any length of time during which bottling orders would ordinarily be changed. However, it is possible that a bottling order may be received between the time the application to bottle is filed and the time the spirits are in bottling tanks ready to bottle, which will affect the bottle sizes to be used and the strip stamps required. Accordingly, part 5 of Form 1515, showing the number and denomination of stamps required, may be executed after the spirits have been dumped for bottling and prior to the actual commencement of bottling operations, at which time the quantities and denominations of stamps required may be more accurately determined.