Obligating Funds for Strip Stamps

A certifying officer of the the Bureau of Alcohol, Tobacco and Firearms (ATF) requested an advanced decision as to whether it may obligate annual appropriations at the end of the fiscal year for orders of strip stamps placed with the Bureau of Engraving that are printed or in the process of being printed. It was also asked if the unfilled portion of that order can be automatically charged to the next fiscal year appropriation without an additional order being placed. Strip stamps are attached to containers of alcohol to indicate compliance with the Federal excise tax on liquor. The stamps are provided free to private parties who order them through ATF field offices. After the orders are processed at ATF headquarters in Washington, sufficient requisitions are placed with the Bureau of Engraving to fill the outstanding orders. The Bureau prints the stamps, ships them to the private individuals ordering them, and bills ATF for its costs. ATF reimburses the Bureau from appropriated funds available for this purpose. ATF obligates funds on the last day of the month to cover all orders placed during the month. It was held that regardless of whether ATF places orders for strip stamps with the Bureau pursuant to either 31 U.S.C. 686 or 26 U.S.C. 6801, it may obligate annual appropriations at the end of the fiscal year to the extent stamps are printed, in process, or under contract. GAO would not object to the ATF automatically obligating its next fiscal year's appropriation to cover the remainder of the order based on information provided by the Bureau on the extent to which it has been filled as of the close of the fiscal year.