I’ve backed up my statements with two conversations today with the ATF. Both without hesitation said it’s a lower and the owner can build it , disassemble it and build it again going from rifle to pistol etc… I encourage you to do the same and talk with the ATF as no one else so far has seemed to do. If you get a different answer than I received I would greatly appreciate the name and number so I can put them in touch with my agents and let them hash this out.
Thanks and good luck.
My apologies, it was quoting this letter from the ATF and it was using T/C ruling in it.What you claim as a quote from T/C (504 US 505) does not appear in the referenced document
It is not just a letter from the ATF, it is ruling 2011-4, which is still valid according to https://www.atf.gov/rules-and-regulations/firearms-rulings It is an official position taken by the ATF.
It addresses parts kits such as the T/C kit. It addresses constructive intent where the parts do not need to be assembled for a violation to occur. It also addresses that the “weapon made from a rifle” subsection occurs when "produced from a weapon originally assembled or produced only as a rifle."Specifically, ATF has been asked to determine whether such a pistol, once returned to a pistol configuration from a rifle, becomes a “weapon made from a rifle” as defined under the National Firearms Act (NFA).