Are you referring to Chow v. State from 2006? Believe that was a case in Prince Georges County that made it through the Court of Special Appeals and the Court of Appeals.
A DC police officer loaned one of his handguns to a buddy that had had his guns taken away by the police. The loan was so the buddy could see if he liked the handgun and if he wanted to buy it. The Court held that a loan is not a transfer. So, we have the definition of "transfer" sorted out via Chow. Thing is, it does not deal with "receive" or "possess".
Ahhh, I see what you are saying.