Dear Client: TTB has accepted a $2.5 million offer in compromise from Heineken USA "for alleged violations of the Federal Alcohol Administration (FAA) Act," the agency just reported. WHAT HAPPENED? First off: Heineken's offer in compromise is not an admission of guilt (as alleged wrongdoing parties often offer monetary "OICs" in exchange for the TTB to not take the case they've built for judicial review; the dollar amounts are getting steeper [see BBD 09-13-2018]). Indeed, the brewer said, "The settlement
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