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June 23.2009

Alternating Proprietors - Hot Topic at TTB Expo

by Susan Cagann

TTB has been strictly enforcing a new policy when examining applications of alternating proprietors.  TTB examines these applications to determine whether the applicant will control winemaking and take responsibility for production decisions, winemaking functions, record keeping and tax payment.  In recent months, TTB has asserted that no host winey employees may perform work for an alternator.  This fairly new interpretation is purportedly based on Industry Advisory 2008-4.  The plain language of the advisory does not forbid host winery employees from performing work.  Rather it states that the totality of the circumstances will be taken into account by TTB analysts.  We are meeting with TTB officials this week at TTB Expo in Cincinnati to explore TTB's new policy and to discuss the negative implications of this policy for real world winery operations.

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