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Looking at Tank's letter (thanks for posting that, by the way), the paragraph about assembly and barreling begs a series of questions. On page 2 it says:

"With respect to barreling and the assembly of pistols, if the individuals utilize a receiver that has never been barreled as a rifle action, they may lawfully assemble a pistol. Such an assembled pistol would constitute a "firearm" as defined by the GCA. If an individual utilizes a receiver that has already been barreled as a rifle action in the assembly of a pistol, such an assembled pistol would constitute a "weapon made from a rifle" as defined in the NFA." [see attachment below....]

1. For NFA and GCA purposes, does "receiver" include both the upper and lower halves of an AR15 assembly, or does it include only the lower half with the serial number?
2. If #1 includes both the upper and lower halves in the definition, why is the lower the only one with the serial number, and the only one which requires an FFL to transfer, while I can mail order any assembled upper or upper parts I want without including an FFL in the transaction?
3. If #1 does NOT include both halves in the definition, what is to stop me from having a pistol lower with one of those Sig (or other similar) braces, and multiple uppers with rifle, carbine, and pistol length barrels with appropriate optics?
4. Regardless of whether #1 includes both halves in the definition, If I bought a stripped lower at a gunshow, and I assembled it into a rifle, shot it for a while, and then I later rebarreled the upper receiver to 7", removed the rifle/carbine buttstock and reconfigured it as a pistol, possibly with a Sig or other brand of brace, how on earth is BATFE going to know what the original use was, and whether it was modified or not subsequent to that? After all, a declaration of intended use was not a part of the original purchase transaction.
5. Last question..... Hypothetical Scenario: I have an SKB double rifle case, inside of which are found two complete upper assemblies, and two complete lower assemblies, none of which is actually mated to the other:
   
   1. an assembled AR "pistol" lower, minus any fancy brace, with just the usual padded buffer tube, assembled using a stripped lower purchased from an FFL at a gunshow.
   2. an assembled AR rifle/carbine lower, with a 6 position collapsible buttstock, assembled using a stripped lower purchased FTF from a friend across town, which was originally purchased as a stripped lower from a local gunstore.
   3. an assembled AR upper with a 7" barrel and a Magpul AFG.
   4. an assembled AR upper with a 16 M4 profile barrel and a vertical foreward grip.
   Is there anything illegal about this collection in this rifle case? After all, it IS possible to configure an unregistered SBR by mating the the pistol upper to the carbine lower........however, that is not the condition in which they are found. Would the legal situation be any different if the carbine and pistol receiver halves were already properly mated together into a pistol and a carbine when found?

Can someone with practical experience.....preferably with an FFL....tell me what the law says in this kind of situation? Speculation is useless because I simply don't trust legal authorities to not interpret the situation to my disadvantage, even though the law appears to be vague here, and I have not done something overtly (and obviously deliberately) illegal.

And just to reiterate, this is a hypothetical scenario. I do not own any ARs of barrel length less than 16".

carlson1 wrote:Here is mine with cheek riser. Again 11.5 Spikes.

Well gee..... that looks kind of familiar.