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Comments regarding Draft Uniform Schedules Dated August 13, 2013

No comments regarding the format of any of the 3 uniformity schedules. All comments relate to clarification of information requested.

Please provide draft “electronic filing Table of Codes” for each schedule so that we may review and consider programming implications of these tables.

We stress yet again the request to exclude “little cigars” from these schedules. Either that or request all taxing jurisdictions adopt a uniform definition of “cigarette”. Without this uniformity of definition it will be extremely difficult, if not impossible, to reconcile ending inventory across all taxing jurisdictions. This comment was echoed again and again by all AWMA distributors providing input to this response.

Please confirm that the intent of these uniformity schedules is to replace Cigarette, PACT and MSA/NPM filing requirements in each taxing jurisdiction in which these forms are adopted.

Please confirm that the purpose of these forms is to disclose the physical movement of cigarette inventory during the reporting period. That is, for the “Home” State the forms should disclose all cigarette inventory entering and leaving the distribution facility during the reporting period irrespective of when the related costs are posted through the Accounts Payable system. For an “out-of-State” filing, the reconciliation should be of that State’s stamped product.

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