This is in reference to your correspondence to the Bureau of Alcohol,Tobacco,Firearms And Explosives(ATF) Firearms Tec Branch in which you inquire about the configuration(s) and reconfiguration(s) of certain firearm kits which include both rifle and pistol components
It is the position of the ATF that if a multipurpose firearm kit containing the above-listed
components is obtained as an assemblage of parts from a single source, the components of the kit
may be assembled and subsequently reassembled an unlimited number of times as a rifle or a
pistol. Please note, however that the assembly of a rifle having a barrel length of less than
16 inches from the components of a multipurpose firearm kit would still require the submission
and approval of an ATF Form 1 "application to make and register a firearm" , this is because
short-barreled rifles are subject to the National Firearms Act
We thank you for your inquiry and trust that the foregoing has been responsive.
Sincerely yours
John ABCD
They are addressing the kit from the Supreme Court case.
I still think that its limited to the kit only.
Anyway I just sent out a letter to othe BATF asking for clearification
of the following
Question 1. Would it be a violation of the law to change a
Contender pistol (purchased originally as a pistol from the
manufacturer in 1995) from a pistol configuration to a
rifle configuration (with a shoulder stock and 18 inch barrel)
and then back to a pistol configuration
(no stock and 10 inch barrel)?
Question 2. Would it be a violation of the law to change a
Contender rifle (purchased originally as a rifle from the
manufacturer in 1995) from a rifle configuration
(shoulder stock and 18 inch barrel) to a
pistol configuration (no shoulder stock and 10 inch barrel)?
Question 3. My 3rd question relates to the Contender pistol and carbine kit
specifically addressed in the 1992 U.S. Supreme Court case United States v. Thompson/Center Arms. Would it be a violation of the law to
assemble the this specific kit as a rifle (shoulder stock and barrel
over 16 inches) and then to later reconfigure this same rifle into
a pistol configuration (no shoulder stock and barrel shorter
than 16 inches)?
Question 4. Would it be a violation of the law to change an
Encore pistol (purchased originally as a pistol from the
manufacturer in 2005) from a pistol configuration to a
rifle configuration (with a shoulder stock and 18 inch barrel)
and then back to a pistol configuration
(no stock and 10 inch barrel)?
Question 5. Would it be a violation of the law to change an
Encore rifle (purchased originally as a rifle from the
manufacturer in 2005) from a rifle configuration
(shoulder stock and 18 inch barrel) to a
pistol configuration (no shoulder stock and 10 inch barrel)?
