A promoter sequence between nucleotide -51 and nucleotide -10 in the human alcohol dehydrogenase gene ADH2 has been shown to bind the transcription factor CCAAT/enhancer-binding protein (C/EBP). A series of 5'-end deletions of the ADH2 promoter was cotransfected with a C/EBP expression plasmid in a human hepatoma cell line, and trans activation by C/EBP was seen when at least 171 base pairs of 5'-flanking DNA was present. Mutations in the ADH2 promoter indicate that the mechanism of C/EBP trans activation involves two binding sites, one located just upstream of the TATA box and one located in an unusual location between the TATA box and the transcription start point.