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ATF letter regarding manufacturing of firearms released 1/2/2015

I can see the logic of ATF's position, as applied to businesses that regularly do gunsmithing work and are "engaged in the business" as the law says.
If they can't do the work themselves directly, they can't sell you the use of their shop and equipment and supervision while you push the "go switch" and mill yourself a lower, turn down a disc to make a silencer baffle, etc.

Now what I'd like to do is apply for a Form 1 to make my own silencer, and then enlist the help of a non-gunsmith machine shop to supervise me and advise me while I use their machines to make the silencer to the specs and dimensions that ATF has already approved. And this shop wouldn't be "engaged in the business" of making firearms or gun parts or doing gunsmithing work. They'd just get folks like me as "customers" once in a blue moon.

So how is this ATF ruling supposed to apply, if at all, to private "build parties" among private individuals who do not even operate a machine shop or gunsmith shop, but just happen to have the right power tools to turn an 80% lower into a finished and functional lower? ATF says that making guns is engaging in the business, and just clamping the gun into a CNC machine and then removing it from the machine (after the customer has done the metal cutting) is itself "distribution" of firearms, and thus engaging in the business. That doesn't sound right. It doesn't fit the letter of the law or the spirit behind it. Occasional transactions do not mean one is "engaged in the business."
But who has the budget to fight ATF in a civil suit, and who wants to risk federal prison time by using that as a defense in a criminal case? Not me.
 
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