Rev. Rul. 54-449

Advice is requested whether the value of an internal revenue bonded warehouse building and equipment therein which are located on the distillery premises must be included in the penal sum of an indemnity bond, Form 3-A.

Section 2800(e)(1) of the Internal Revenue Code of 1939 provides that a lien attaches to the distillery, the stills, vessels, fixtures, and tools therein, the lot or tract of land whereon the said distillery is situated, and on any building thereon.

The term `any building` as used in section 2800(e)(1) of the Code includes an internal revenue bonded warehouse or any other building located on the distillery premises, whether or not such building is used for distilling purposes. The value of all such buildings should be included in the penal sum of the bond filed on Form 3-A, `Leaseholder's Bond for Distillers,' in accordance with section 183.143 of Regulations 4, or on Form 3, `Bond of Indemnity in Favor of the United States,' in accordance with section 183.147 of Regulations 4.