View Full Version : What does TTB want in terms of how tax will be figured out? Please help.

That New Guy
12-14-2016, 09:01 PM
I'm in the final review stages for my brewer's notice from the TTB and twice now they have had me rewrite the part about how I will figure out the taxes on the beer. I tried writing in detail that I would measure the beer in the brite tanks and use those as tax determination tanks, but they said that would only work if I am a brewpub. Then I wrote in detail that I would measure everything that goes into the kegs and use that as my measurement since everything will be kegged before being sold, or tapped for sales in the tap room. My agent is nice enough but not answering my questions. What exactly are they looking for in response to this portion of the application? Am I supposed to get into fractions and math or something super detailed like that? I'm just so frustrated and really could use some guidance on what other breweries wrote for this section, or if maybe they got directions from their review specialist on how to answer this satisfactorily. I'm a small brewery, 7bbl system, with a small taproom, on a farm. Can anyone out there please help me understand what I am supposed to write and then do to get this correct.

Thanks in advance. I'm in day 11 of my 15 days or we consider this abandoned, despite responding rapidly and most of those days were spent with all the information they asked for under review. I got that part wrong again and really don't want my application to be abandoned because I can't answer this one question.

Thank you. And Please.

12-14-2016, 09:33 PM
You need to have all the beer that will be in Bonded and then moved to Taxable.
Spreadsheet Printable movements of product is all they care about.


12-15-2016, 07:49 AM
I think the confusion comes from the term "brewpub". For most people, a brewpub is a restaurant that makes it own beer. For the TTB, you are a brewpub if you are serving your own beer at a taproom that is attached to a brewery. They don't care if you are a restaurant or have food at all. I think you should look in to calling yourself a brewpub for TTB purposes. Then say that your tax determination tanks are 1/2bbl tanks (kegs). Once the beer is moved from the brite tank to the tax determinations tanks they must be held in an area that is marked as tax determined.

For me that means moving the beer from one side of the walk in cooler to the other. Anything past the line on the floor is tax determined, and yes there has to be a line on the floor.

Troy Robinson
Quirk Brewing
Walla Walla

02-18-2017, 06:47 PM
I dunno about that... I think when it's in the keg, it's too late. The bright tank should be the tax tank. You calculate when you are done transferring into it. At that point it's considered finished alcohol. You may then serve it or package it. I'm not so sure about the brewpub comment either. You certainly don't want them hunting you down to prove at least 40% of your sales were food. Might be time to spend some money with TTB associates or beerlawcenter and learn how to do this properly.

02-20-2017, 09:39 AM
When you look at the forms, you pay tax on all the beer sold. However, you report the volumes to the cellar, to the brites and to keg/bottle, they are looking for discrepancies ie: you had 18bbl in the brite, but you kegged 20bbl of beer, this is a problem for them, either short filled kegs or you added water.
Tax determination is usually done when the beer moves to the brites from the cellar, you need a drawing showing where the "bonded" area is, this is the area where the beer has not been tax determined yet. Also needs to show where the tax determined area is. You also need to provide the details of how you will measure the tax determination vessel volume, ie: sight glasses, flow meters, differential pressure gauges, etc. On top of this, you need to show how you will periodically calibrate these methods. For sight glasses, you would need a way to put a measured amount of water in and verify that it moves up the sight glass the proper amount.