Rev. Rul. 55-594

Advice has been requested whether taxpaid vodka distilled from grain and bottled at a rectifying plant may be labeled as grain neutral spirits.

Revenue Ruling 54-493, C.B. 1954-2, 472, provides that vodka produced from grain at 190 degrees of proof and otherwise eligible for classification as `Neutral Spirits-Grain' may be so reclassified prior to taxpayment and withdrawal from an internal revenue bonded warehouse.

Section 21, class 1(a), of Regulations No. 5, defines vodka as neutral spirits distilled from any material at or above 190 degrees of proof and further subjected to one of the refining processes specified therein. Therefore, under the standards of identity, such spirits are neutral spirits. Accordingly, they may be so labeled for bottling as neutral spirits and for use in blended whisky. However, neutral spirits which have not been subjected to one of the refining processes specified in section 21, class 1(a), would not be entitled to the designation vodka.

Taxpaid vodka received at a taxpaid bottling house or at a rectifying plant may be reclassified as grain neutral spirits and so labeled when bottled, provided the vodka was produced from grain neutral spirits at a registered distillery in accordance with the regulations. This ruling does not apply to vodka produced at a rectifying plant under exemption from the rectification tax