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#31 HB of CJ

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Posted 16 February 2016 - 11:57 AM

Agreed.  We will see.  Will Advise. HB



#32 unforgiven

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Posted 16 February 2016 - 01:22 PM

Ask 5 agents a question..

Get 5 different answers

 

 

Always go to the books, in a pinch they will be the only leg you can stand on!


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#33 Ronin38

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Posted 16 February 2016 - 10:35 PM

Yeah, when I was in flight training many years ago, we actually had a class project where we would call the FSDO (Flight Standards District Office) several times during the week. These are the "Officials" you call for "Official" answers to questions about "Official" Flight Rules... Like any Government Organization, you ask 5 different people the same question and you'll get 5 different answers! Oh, did I mention you could LOSE YOUR PILOT'S LICENSE if you guess wrong on one of those rules?

 

Yeah...  :unsure:


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#34 HB of CJ

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Posted 16 February 2016 - 11:09 PM

Very interesting.  Understand this has NOT been confirmed by written Current Written BATFE opinions.  Trust but verify.  We are having a failure to communicate?  It appears we are confusing Apples with Oranges.  Also understand current rulings do change dealing with the BATFE.

 

Manufacturing vs. Converting or Modifying   A BATFE legal distinction.  Also very poor language used by the BATFE.  Converting or Modifying a rifle receiver into a SBR that already has the serial number and company information on the receiver DOES NOT HAVE TO BE ENGRAVED.

 

Why?  The receiver has all ready been manufactured by the factory.  The information needed for the SBR is already on the receiver.  The BATFE goes by that.  The Form 1 tax stamp owner is only MODIFYING or CONVERTING it into a SBR on the Form 1.  A source of great confusion.

 

The tax stamp only is in effect with a short barrel.  As with the Ruger 10-22, simply installing a regular length barrel  removes the receiver from the burden of being a SBR NFA item. It instantly becomes just a ordinary rifle.  Reinstall the short barrel listed on the Form 1?  Now a SBR.

 

Important.  Right now only ONE short barrel can be allowed with one SBR Form 1 tax stamp.  We do not know if existing Form 1 tax stamps can be amended to allow multiple short under 16" barrels married to one tax stamp.  Grey area.  Will get a current written ruling on this also.

 

This seems to be a change from the 2008 ruling that allowed temporary multiple short different barrels to be used on one SBR receiver.  The only exception would be if the tax stamp already specifically lists all the different short barrels married to the SBR receiver.  We will confirm.

 

Manufacturing means physically making a gun.  Doing a 80% AR lower would be a good example.  That would have to be engraved with the caliber, owner, city and state.  We will be getting written confirmation on this from the BATFE and will share it here.  Will confirm in writing.

 

Confusing for sure.  Manufacturing a SBR does required engraving.  Modifying or converting a factory marked receivers into a SBR does not required engraving.  The key words are Manufacturing vs. Converting or Modifying.  Again, we are going to get current written rulings.

 

Also important.  The BATFE changes its mind constantly.  Many examples of this.  The AR15 M16 bolt carrier legality is a good example.  Also the swings back and forth regarding the use of temporary multiple short barrels on one SBR tax stamp.  A final frustrating observation here  ...

 

It might be a very good idea to ask the BATFE to provide you with written current ruling specifically regarding your particular NFA tax stamp item.  Rulings change.  The BATFE does NOT publish current ruling to us.  In the future this might be very important to us.  Always get it in writing.

 

Call them yourselves to confirm this.  Also get it in writing.  Also understand the BATFE changes its mind.  Worserer than the IRS.  Yikies! :(



#35 Netpackrat

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Posted 17 February 2016 - 07:42 AM

Wow.  It's been a while since I have seen so much total bullshit distilled into one forum post.  I guess it's your rifle, do what you want with it.  Anybody else reading this and trying to figure out if they must engrave, you can believe some guy's rambling post of assertions with no verifiable source backing them up, or you can just look at the ATF's own guidebook and read what it says you have to do.  And honestly, if you are serious about getting into NFA this is probably the last board you should be looking to for information anyway.  There was a recent thread on Silencertalk (which may still be ongoing for all I know, I haven't checked there in a few days) where this very issue was being discussed, by multiple current SOTs.  It's not rocket science.


Edited by Netpackrat, 17 February 2016 - 07:43 AM.

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#36 DLT

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Posted 17 February 2016 - 08:33 AM

I got lucky and found a retired GM engineer turned gun dealer only an hour from me with a very nice industrial class laser engraver.  He did an awesome job on my two PAP M92's.  I'd show pics, but not really interested in sharing my private info.  I will say he was extremely knowledgeable on the process.  He even had demos around to show the difference in depth between what ATF requires, and what he recommended (which was deeper).  I went with his recommendation and the results were outstanding.   


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#37 HB of CJ

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Posted 17 February 2016 - 11:34 AM

Netpacket;  It is possible our information obtained from the actual AFT agent in San Francisco (?) is dead wrong.  It is possible the enforcement agent is wrong.  Or it is possible ALL OF US misunderstood the difference between MANUFACTURING vs. CONVERTING / MODIFYING.

 

To call such POSSIBLE accurate timely information directly obtained from the BATFE and shortly to be backed up with current rulings BULLSHIT might not be the best response? It MAY be considered more polite just to say this is news to me, WTF, I do not understand and I will confirm?

 

This is what we were told.  I do not know how else to present this.  This will be confirmed IN WRITING like I said in my researched timely post.  To learn new stuff contrary to past efforts, understandings and endeavors is unsettling.  All of this is to me.  I am just the messenger with this.

 

Like already shared, cussed and discussed earlier, the BATFE is well known changing their minds.  Ask 10 agents, get 10 different answers.  Worserer than the IRS.  We will get confirmation both vis Email and USPS and will share with all here.  For what it is worth, I am mad also.

 

I am mad at lots of things right now.  Let us start with current world events, our dog and pony show election process, big politics, big money, the IRS,  my physical condition, outstanding bills, no money, a uncertain future for my young family and others.  We are sharing in our pissed-ness.

 

Except for all the pissed--ness, everything is fine.  Will advise with written BATFE written current relevant rulings.  YIkes! :) :)



#38 Netpackrat

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Posted 17 February 2016 - 04:08 PM

That's JUST what we need, another %$*&^ letter writer....  People like you are the reason why we now have a "ruling" that shouldering a Sig brace constitutes making an SBR.  Any time you write the ATF for "clarification" of something like this, all you are doing is giving them the opportunity to de-facto regulate without going through the rulemaking process.  If you can fricking read the regulations that are already out there, it is not difficult to understand the requirements.  This is not that complex...  People manage to go through this process every day, and understand the marking requirements without having to contact the ATF.

 

Since obviously you don't believe or understand what it says in the guidebook, we can dig a level deeper, into the very regulation that the guidebook is supposed to explain, 27 CFR 479.102:

 

 


ยง 479.102 How must firearms be identified?

(a) You, as a manufacturer, importer, or maker of a firearm, must legibly identify the firearm as follows:
(1) By engraving, casting, stamping (impressing), or otherwise conspicuously placing or causing to be engraved, cast, stamped (impressed) or placed on the frame or
 
receiver thereof an individual serial number. The serial number must be placed in a manner not susceptible of being readily obliterated, altered, or removed, and must not duplicate any serial number placed by you on any other firearm. For firearms manufactured, imported, or made on and after January 30, 2002, the engraving, casting, or stamping (impressing) of the serial number must be to a minimum depth of .003 inch and in a print size no smaller than 1/16 inch; and
(2) By engraving, casting, stamping (impressing), or otherwise conspicuously placing or causing to be engraved, cast, stamped (impressed), or placed on the frame, receiver, or barrel thereof certain additional information. This information must be placed in a manner not susceptible of being readily obliterated, altered or removed. For firearms manufactured, imported, or made on and after January 30, 2002, the engraving, casting, or stamping (impressing) of this information must be to a minimum depth of .003 inch. The additional information includes:
(i) The model, if such designation has been made;
(ii) The caliber or gauge;
(iii) Your name (or recognized abbreviation) and also, when applicable, the name of the foreign manufacturer or maker;
(iv) In the case of a domestically made firearm, the city and State (or recognized abbreviation thereof) where you as the manufacturer maintain your place of business, or where you, as the maker, made the firearm; and
(v) In the case of an imported firearm, the name of the country in which it was manufactured and the city and State (or recognized abbreviation thereof) where you as the importer maintain your place of business. For additional requirements relating to imported firearms, see Customs regulations at 19 CFR part 134
 
This regulation is available here and at other sites.
 
To repeat one more time, when you fill out Form 1, Application to Make and Register a Firearm, you are the MAKER of the firearm.  It does not matter whether the firearm began life as an ordinary (Title 1) firearm, or as a hunk of metal in your shop.  All the former means is that they want you to re-use the existing serial number on your application, and they want to know what the original manufacturer and model was that you are making the NFA regulated firearm from.  As the maker, you are still required to engrave or stamp your name, city, and state on the firearm.  Anybody who says otherwise does not understand the regulation.  If you promote opinion of such people as fact, then you are only contributing to the confusion that already exists, which may cause you or somebody who believes you to get in trouble some day.
 
I don't doubt that you can find plenty of ATF agents who will say you don't have to mark your Form 1 firearms, because there are simply a lot of ignorant and stupid people out there, and a disproportionate number of them work for the government.  But here's another point...  Even if by some stretch you were not required to mark your Form 1 stuff, it doesn't hurt a god-damned thing to do so.  You're not hiding, or flying under the radar by not marking; the $%#*^& ATF already has your information because you registered an NFA item with them.  In fact, if your firearm is stolen, it greatly increases the chance that it may be returned to you someday.  It's a big red flag to any FFL dealer logging a used firearm into their records, that something may be amiss, especially if somebody has placed a 16"+ barrel on a firearm with some guy's trust info engraved on it.  And while you will never get in legal trouble for marking your information on your SBR, someday you might run into an ATF agent (or other LEO) who actually understands the law, and is in a mood to be an asshole about it.
 
And yeah, I am not an FFL/SOT or whatever kind of authority you seem to be looking for.  I'm just a dumb-ass aircraft mechanic...  Which means that I have to be able to read and understand federal regulations and technical documents in order to make my living and keep my license.  If you think the NFA is confusing, you should try to understand the FARs sometime.  I will add that when my boss isn't sure what exactly the manuals allow us to do, I'm one of the guys he asks to hit the books and double check his understanding.
 
Once again, it is your rifle, do what you want to do with it.  Ask enough dealers and ATF agents and you should have no trouble finding many of them who will agree with what you want the law to be, rather than what it actually is.  Or you can read what the regs actually say for yourself.  It's not difficult, you just have to take the time to do it, without regard for what you want them to say.
 
The main reason I am being pissy about this, is you are posting bad info and backing it up with absolutely nothing, besides some vague assertions of having talked to "somebody" who is supposed to be some kind of authority.  For all anybody here knows, you are getting your "info" from the underpants gnome.  The regs are out there for anybody who wants to read them; what you have posted is of no value to anybody.  The second reason is that when you persist on obtaining a new "ruling" that is contrary to the written regs, there is a good chance that you will get one, and in the process fuck over a lot of people who DO understand what the regs say, and cause our advocacy organizations to have to spend time and money to repair the damage done by you and whatever guy at the ATF decides to issue a ruling contradicting the current practice.  And possibly putting a bunch of people into the position of noncompliance with some arbitrary (and incorrect) ruling until it gets straightened out.

Edited by Netpackrat, 17 February 2016 - 04:11 PM.

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#39 HB of CJ

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Posted 17 February 2016 - 05:27 PM

Netpackrat.  I do not know how to precede.  Information is presented to this forum.  You choose to take issue with it.  It is also strongly suggested that you do not accept such information as accurate and to find out FOR YOURSELF if such info is timely and accurate.

 

Then you take issue with anybody, including yourself, taking the important time to CONFIRM via written and Email contact with the BATFE the information just presented on this EXCELLENT FORUM.  No matter what is presented or how, you take exception to such.

 

Why are you choosing to do such?  I am just the messenger here.  Trust but verify.  We are dealing with the 400 pound Gorilla, the BATFE.  Do not believe one word of what was presented here.  Find out for yourself.  Verify.  It is important we get this correct.  Thank you. :( :(



#40 Netpackrat

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Posted 17 February 2016 - 05:36 PM

trollorstupid.jpg



#41 Netpackrat

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Posted 17 February 2016 - 05:47 PM

OBTW, here is a partial list of ways the ATF has fucked us after some schmuck wrote them a letter.  Not my words, copied over from elsewhere:

 


Repair of machine gun receivers particularly M16 receivers by Bushmaster, Colt and Armalite as well as other manufacturers.

Repair/replacement of suppressor tubes. Now after Gemtech's bitchen whine letter ATF damaged tubes can only be shortened. Baffle size must be the same and cannot be reduced or enlarged once it leaves the factory.

Thousands of NFA enthusiasts had to turn in their atkins accelerator stocks.

ATF decided shoe laces could be a machinegun.

922R applies to SBRs and SBSs.

Individuals registering SBRs, SBSs, and AOWs on Form 1s have to engrave their information again after not having to if it was conversion of an already existing firearm.

For a brief time almost all gunsmithing including trigger jobs became manufacturing requiring a manufacturing license.

Part kits with barrels now cannot be imported unless the firearm to which the barrel goes meets the sporting purposes requirements of GCA'68 - commonly known as the barrel ban.

XMG Belt-Fed AR-15/M16 Upper Receiver became post-sample machine guns even though they could not fire full auto without a M16 lower costing MANY MANY law abiding firearms enthusiasts thousands of dollars.


Edited by Netpackrat, 17 February 2016 - 05:49 PM.


#42 HB of CJ

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Posted 17 February 2016 - 05:51 PM

I give up.  You can't satisfy everybody.  You can only satisfy yourself.  Please have a nice day.  Respectfully. HB


Edited by HB of CJ, 17 February 2016 - 05:54 PM.


#43 HB of CJ

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Posted 19 February 2016 - 01:58 PM

This written conformations via the BATFE may take awhile.  Right now they are running it up their own flag pole.  Seems US Code laws trump BATFE opinions.  We already have determined that US Title Code 27 478.11  definitely allows multiple short barrels on a legal registered NFA SBR.  Will advise with the other stuff.  Again, this might take awhile.  Respectfully.



#44 HB of CJ

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Posted 25 February 2016 - 02:50 PM

Update.  Yep ... ask 10 different questions, two 3 different answers.  However ... according to the Portland OR BATFE supervisor I spoke with on the phone, (for whatever that is worth) now engraving receivers with a SBR Form 1 is now OPTIONAL.  Now he says you can have it on the butt stock or the single barrel and NOT THE RECEIVER.  WTF?

 

Also new Form 1 SBR receivers can have only ONE barrel and ONE overall length per Form 1.  Temp use of multiple barrels per US Code now does not apply?  Use of any other length SB with the Form 1 SBR receiver now requires ANOTHER Form 1.   WTF?  I am only the messenger.  That is what he told me.  Complete BS in my opinion only.

 

So there you have it.  I for one am NOT going to take this to the bank.  I will NOT be pursuing this any further.  Down the Rabbit Hole we go.  Alice and Wonderland.  Our kicked back multiple barrel Form 1 Ruger 10-22 SBR WILL BE ENGRAVED.  Do not take phone call info seriously.  We deal with the 400 pound Gorilla at our Peril.  Very sad.



#45 unforgiven

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Posted 25 February 2016 - 04:05 PM

giggle



#46 HB of CJ

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Posted 25 February 2016 - 04:53 PM

Entire post deleted by HB of CJ


Edited by HB of CJ, 25 February 2016 - 05:06 PM.


#47 HB of CJ

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Posted 25 February 2016 - 05:07 PM

Giggle all you want.  Easy to giggle.  Harder to attempt to take corrective action with the BATFE.  They remain the 400 pound Gorilla.  Respectfully.



#48 unforgiven

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Posted 25 February 2016 - 05:08 PM

I am only giggling at the ATF for being so incapable of accurate answers.

As I stated before in this thread, ask 5 agents get 5 answers.

The funny thing was you deciding to protect yourself after getting multiple answers. 

 

How you take my comment as some kind of personal attack is plain stupid.

But obviously worth call me names

 

I MANUFACTURE firearms...I deal with ATF ALL THE TIME, I call tech branch frequently!!

I have paid for so many tax stamps I should be a philatelist....Thats a "stamp collector" to you

 

So bring it mods I made fun of the ATF........... 


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#49 HB of CJ

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Posted 25 February 2016 - 05:14 PM

Please read my deleted post which was deleted.  Since you deal with the BATFE on a daily basic, why don't YOU write or call them up and YOU get it in writing?  Just a thought.


Edited by HB of CJ, 25 February 2016 - 05:15 PM.


#50 Netpackrat

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Posted 25 February 2016 - 06:10 PM

haha.jpg

 

At least you didn't get anything in writing. 


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#51 unforgiven

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Posted 25 February 2016 - 06:14 PM

I my opinion, and past experience.....

Forcing ATF into a written opinion....has never ended well



#52 Atomic Punk

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Posted 04 March 2016 - 04:58 PM

Getting a verbal opinion from anyone at the BATFE is only worth the paper it is written on. 

 

There is an interview from a news program out there where a senior BATFE official says an airsoft gun can easily be converted into a machinegun. 


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#53 Netpackrat

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Posted 05 March 2016 - 01:22 AM

I seem to recall that they did put the kibosh on some airsoft ARs that would accept too many parts from the real thing.



#54 Roadhawg

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Posted 07 March 2016 - 05:16 PM

 I had mine engraved a fairly simple process and not that expensive.

Sure will make life easier for the wife some day, if she becomes a beneficiary and has to sell it.


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#55 Roadhawg

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Posted 09 March 2016 - 04:14 PM

Here is one opinion letter............

Attached Files



#56 HB of CJ

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Posted 11 March 2016 - 12:06 PM

Nice letter Roadhawg and thank you.  I can not read it and have no way of doing so.  Anyway you enlarge it for us?  I think this whole thing started with a failure to communicate.  Referring to the NFA hand book, (or their list of regulations) 7.4.2 does say frame, receiver, or barrel.  Either Or.  This is probably where it all started.  Engraving receivers on a Form 1 SBR is optional. 

 

But ....

 

The only zinger is that you still must engrave, only you have an option of putting it on the barrel instead of the receiver.  Or on the frame if that applies.  Miscommunication. Yikes!  All of our existing Form 1 stuff is engraved.  We were told with the new-to-be Form 1 SBR, engraving on the receiver was optional.  What we were not told was the rest of the whole story.  Unfortunate.  :(



#57 GunFun

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Posted 11 March 2016 - 03:18 PM

His thing above says:

 

0) that if you form 1 YOU are now "the maker." Therefore, it needs your info. You can reuse the original serial, but there is info you must add.

 

1) it can be on the barrel or receiver. - if you are dumb, you use the barrel and now can't rebarrel your registered gun when it is worn.

2) Must be hard to obliterate and .003" deep

3) must have model # if designated.

4) an individual serial #. -- can be original.

5) as "maker",  your name.  

6) as "maker" your city, state


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#58 HB of CJ

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Posted 11 March 2016 - 06:21 PM

Yep.  Pretty straight forward. 



#59 Netpackrat

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Posted 12 March 2016 - 06:34 AM

But, if you refer again to the regs, you may note that the one item that must still be engraved on the frame or the receiver is the serial number.  Not an issue if you are registering an existing firearm, but important to remember if you are submitting a form on an 80%, silencer, or other homebuilt item.  I saw on another forum where a guy engraved his trust info on every barrel that he intended to use with his SBRed AR lower.  Not the way I would do it, but is legal....  You can still rebarrel your SBR, you just have to make sure the new barrel is also engraved.  Multiple configurations are OK as long as you can still return it to what is listed on the form.  And of course it only makes sense to put the caliber/gauge on the barrel and not the receiver.



#60 HB of CJ

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Posted 14 March 2016 - 02:00 PM

Time to retire this sad entire thread.  The question and input was that engraving receivers on a Form 1 SBR was not required?  Seems this is true as stated?  Completely true.  The failure was that some parties did not choose just to say they did not understand.  Their reactions were non professional, personal and ugly.  Not good.  Again ... for some reading this, engraving receivers on a SBR Form 1 is not required. 

 

However ...

 

But ... and here is the other boot dropping, engraving is still necessary.  One has the choice of either the receiver, frame or barrel.  With the Ruger 10-22, engraving the receiver is the logical choice.  However ... it is not the legal choice.  A great distinction. Again, one has the choice of either the receiver, frame or barrel.  That is the NFA law.  This is an Excellent Forum.  It is regrettable that input was non professional.

 

All Oregon, US Code Law And NFA Rules Apply.







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