199 deduction-definition of Sale

[jmc]

Code 199(c)(4)(A) reads "domestic production gross receipts” means the gross receipts of the taxpayer which are derived from (i) any lease, rental, license, sale, exchange, or other disposition of (I) qualifying production property which was manufactured, produced, grown, or extracted by the taxpayer in whole or in significant part within the United States,

Then, does the deduction apply to any wholesaler or retailer, who are not producer or manufacturer, whose gross receipts are from "sale" of QPP manufactured, produced in US? I researched a few sources but those does not provide specific definition which clears this. Is there any sources defining this point?

[jainen]

owner/producer

Since you aren't asking about a specific client I can only give a general answer. You should do some research with RIA or some other service.

The deduction is only available to the actual owner/producer. Agents, dealers, jobbers, brokers, suppliers--none of them qualify. (For construction contractors only, both the general contractor and a sub can deduct on the same production, which can be owned by a third party.)

[cpadan]

see Prop. Reg. 1.199-4(f)(2)
Dan