Rev. Rul. 54-302

Advice is requested whether a single permit, Form 1447, may be issued, to a state or municipal subdivisions thereof, covering the use of tax-free alcohol at more than one location.

A city has several high schools under the jurisdiction of its Board of Education. A separate permit on Form 1447, `Application and Basic Permit to Use Alcohol Free of Tax by States, Municipalities, Hospitals, Colleges, Scientific Institutions, Etc.,' was issued for each such high school. Since the permits are issued on an annual basis, this necessitated the renewal or several separate permits each year. Also, the tax-free alcohol received under each permit had to be stored at the high school to which that permit related.

The Board of Education of the city here concerned asks permission to file an amended application on Form 1447 for a single permit to use tax-free alcohol in the various high schools under its jurisdiction and for permission to store the alcohol in a locked storeroom in a central warehouse and to make distribution therefrom, pursuant to formal requisition by the high schools using tax-free alcohol, of small quantities of the alcohol required by them for immediate use.

Section 182.165(a) of Regulations 3 provides in part that applications by municipal subdivisions of a State or Territory shall be made to the Assistant Regional Commissioner, Alcohol and Tobacco Tax, by the officer duly authorized to procure such alcohol and that evidence of such authority shall be submitted with the application.

It is held that a blanket permit may be issued, pursuant to section 182.165(a) of Regulations 3, authorizing the use of tax-free alcohol by a State or municipal subdivision thereof in any number of institutions under its control, provided the method of storing, distributing, and accounting for the alcohol withdrawn under such permit is satisfactory to the Assistant Regional Commissioner, Alcohol and Tobacco Tax, and conforms to the applicable requirements of Regulations 3.