Rev. Rul. 56-644

A request has been received for the approval of Form 1656, Transfer of Distilled Spirits or Wines Between Export Storage Rooms, prior to the receipt of the completed bottling records and for the reporting of the required information relating to drawback rates at later date.

Under the provisions of section 252.71 of the Regulations relating to Drawback on Liquors Exported, spirits or wines dumped for bottling without rectification, or dumped and rectified for bottling or packaging, may be bottled or packaged, in whole or in part, especially for export with benefit of drawback. Section 252.86 of the regulations provides that distilled spirits or wines bottled or packaged especially for export may, pursuant to an approved application on Form 1656, be transferred to an export storage room established at the port of exportation for storage pending removal for direct exportation or use as supplies on vessels or aircraft.

Copies of Form 1656 are forwarded to the Assistant Regional Commissioner, Alcohol and Tobacco Tax, for establishment by him of the rate of drawback on the distilled spirits or wines covered by the application. However, he cannot make such determination or dispose of the Forms 1656 until completed Form 230, Description and Gauge of Spirits or Wines for Bottling Without Rectification, or Form 237, Report of Rectified Spirits and Wines, and other related forms, where required, are received by him. In many instances, these latter forms are not received by the Assistant Regional Commissioner for several days after he has received the Forms 1656, thus resulting in a considerable delay in disposing of Forms 1656 and in the subsequent preparation of Form 1582, Drawback on Distilled Spirits Bottled or Packaged Especially for Export, or Form 1582-A, Drawback on Wines Bottled Especially for Export, as the case may be, as well as a delay in exporting the spirits involved.

In order to eliminate this delay, the bottler or exporter of the distilled spirits or wines may prepare an extra copy of Form 1656 and, immediately on approval of all copies and release of the spirits by the storekeeper-gauger in the usual manner, forward the extra copy to the consignee at the port of exportation for use in preparing Form 1582 or Form 1582-A. In such case, a notation should be made by the consignor in part 3 of the extra copy to the effect that the drawback rate will be determined later and that the copy of Form 1656 containing the drawback rate will be forwarded by the Assistant Regional Commissioner of the consignor's region at a later date. The copies of Form 1656 required by the regulations should be processed in accordance therewith.