26 U.S.C. § 5011: Income tax credit for average cost of carrying excise tax

which were bottled in the United States, and which are purchased by such wholesaler during the taxable year directly from the bottler of such spirits, or any person which is subject to section 5005 and which is not an eligible wholesaler, the number of cases of bottled distilled spirits which are stored in a warehouse operated by, or on behalf of, a State or political subdivision thereof, or an agency of either, on which title has not passed on an unconditional sale basis, and the average tax-financing cost per case for the most recent calendar year ending before the beginning of such taxable year. For purposes of this section, the term “eligible wholesaler” means any person which holds a permit under the Federal Alcohol Administration Act as a wholesaler of distilled spirits which is not a State or political subdivision thereof, or an agency of either. For purposes of this section, the average tax-financing cost per case for any calendar year is the amount of interest which would accrue at the deemed financing rate during a 60-day period on an amount equal to the deemed Federal excise tax per case. For purposes of paragraph (1), the deemed financing rate for any calendar year is the average of the corporate overpayment rates under paragraph (1) of section 6621(a) (determined without regard to the last sentence of such paragraph) for calendar quarters of such year. For purposes of paragraph (1), the deemed Federal excise tax per case is $25.68. The term “case” means 12 80-proof 750-milliliter bottles. The number of cases in any lot of distilled spirits shall be determined by dividing the number of liters in such lot by 9.