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Can I de-SBR my pistol to travel to another state w/o permission?
1/22/2012 4:47:32 PM
I'm thinking about adding a folding stock to my 5.56 pistol.
But I like to drop that pistol in my bag when I'm traveling to other states. If it's an SBR, I would have to ask BATFE's permission to take it w/ me out of state.
So ... what if I just remove the stock and travel with it configured as a pistol and put the stock back on when I get back home? Is that legal? Or does it remain an SBR (legally) even w/ the stock removed?
Thanks!
But I like to drop that pistol in my bag when I'm traveling to other states. If it's an SBR, I would have to ask BATFE's permission to take it w/ me out of state.
So ... what if I just remove the stock and travel with it configured as a pistol and put the stock back on when I get back home? Is that legal? Or does it remain an SBR (legally) even w/ the stock removed?
Thanks!
1/22/2012 6:44:09 PM
Most recent ruling from the ATF (keep in mind that changes) is that as long as a particular weapon isn't in an NFA configuration, it isn't subject to the NFA, no matter what its registration status. So, converting a SBR back to a pistol and then crossing state lines with it is fine, at least right now.
1/23/2012 5:34:21 PM
I do it all the time we have our lower SBRed to our house in Wisconsin. its a colt le6945 10 inch barrel. When I want to take back to my parants back in corrupt state of Illinois i just throw on the 16 inch upper and all good to go .
1/23/2012 5:52:38 PM
Good to know.
I always just assumed the lower was the NFA item, and no matter what needed to go through the proper channels.
I always just assumed the lower was the NFA item, and no matter what needed to go through the proper channels.
1/26/2012 8:47:49 PM
Yes you can put a 16" barrel and it takes it out of the purview of the NFA. It is a title one firearm again.
But no, you cannot simply remove the stock and travel as a pistol.
In order to legally swap from a rifle or firearm to a pistol (as per ATF 4-2011) it had to start as a pistol. In the case of a SBR it starts as a NFA firearm, remember the form 1, applications to MAKE a firearm. You made the firearm that is why you must engrave your info as any manufacture does. So it stated life when you made it, as a SBR, not a pistol.
Simply removing the stock does not make it into a pistol, its just a SBR with the stock removed.
But no, you cannot simply remove the stock and travel as a pistol.
In order to legally swap from a rifle or firearm to a pistol (as per ATF 4-2011) it had to start as a pistol. In the case of a SBR it starts as a NFA firearm, remember the form 1, applications to MAKE a firearm. You made the firearm that is why you must engrave your info as any manufacture does. So it stated life when you made it, as a SBR, not a pistol.
Simply removing the stock does not make it into a pistol, its just a SBR with the stock removed.
1/27/2012 5:05:57 PM
So as INeXile says no not really. As cheap as lowers are these days why not just build a pistol lower, it may not have some fancy brand name or be part of some fan club but for about $150 you can pretty much put one together and not have to skirt any laws.
1/27/2012 7:01:54 PM
Actually, when you remove the stock and replace it with a pistol buffer group, you can legally own and carry it as a pistol. The ATF would like to be advised that it is no longer a SBR and they are supposed to annotate the registry accordingly.
The problem comes in reattaching the stock when you return home. Having re-made the SBR into a pistol, changing it back would legally require you to submit the Form 1 AGAIN, pay the tax AGAIN, and wait until the Form was returned AGAIN.
It doesn't appear that your question includes those steps. Could you do what you are asking without going to jail or losing the firearm? Probably. Would I want to chance it knowing that I can buy a complete lower for less than the tax stamp? Not real likely.
You could always write a letter to the ATF removing the SBR status on the gun (and I always recommend including a copy of your Form 1 or 4 when you do that) and tuck it away to be mailed at the same time your NOK comes to make your bail. Who is to say that the letter didn't get delayed in the mail? Update the letter each time you leave the state and then destroy it when you get home. Just keep in mind that if you ever forget to go through all that, karma may be looking for you.
Having said all of that, I am concerned about the apparent contradiciton internal to the ATF opinion
especially in the use of the words "originally made" when referring to the handgun. So I might just write them a letter.
The problem comes in reattaching the stock when you return home. Having re-made the SBR into a pistol, changing it back would legally require you to submit the Form 1 AGAIN, pay the tax AGAIN, and wait until the Form was returned AGAIN.
It doesn't appear that your question includes those steps. Could you do what you are asking without going to jail or losing the firearm? Probably. Would I want to chance it knowing that I can buy a complete lower for less than the tax stamp? Not real likely.
You could always write a letter to the ATF removing the SBR status on the gun (and I always recommend including a copy of your Form 1 or 4 when you do that) and tuck it away to be mailed at the same time your NOK comes to make your bail. Who is to say that the letter didn't get delayed in the mail? Update the letter each time you leave the state and then destroy it when you get home. Just keep in mind that if you ever forget to go through all that, karma may be looking for you.
Having said all of that, I am concerned about the apparent contradiciton internal to the ATF opinion
especially in the use of the words "originally made" when referring to the handgun. So I might just write them a letter.2/1/2012 6:52:31 PM
Originally Posted By MasterSergeantA:
Actually, when you remove the stock and replace it with a pistol buffer group, you can legally own and carry it as a pistol. The ATF would like to be advised that it is no longer a SBR and they are supposed to annotate the registry accordingly.
The problem comes in reattaching the stock when you return home. Having re-made the SBR into a pistol, changing it back would legally require you to submit the Form 1 AGAIN, pay the tax AGAIN, and wait until the Form was returned AGAIN.
It doesn't appear that your question includes those steps. Could you do what you are asking without going to jail or losing the firearm? Probably. Would I want to chance it knowing that I can buy a complete lower for less than the tax stamp? Not real likely.
You could always write a letter to the ATF removing the SBR status on the gun (and I always recommend including a copy of your Form 1 or 4 when you do that) and tuck it away to be mailed at the same time your NOK comes to make your bail. Who is to say that the letter didn't get delayed in the mail? Update the letter each time you leave the state and then destroy it when you get home. Just keep in mind that if you ever forget to go through all that, karma may be looking for you.
Having said all of that, I am concerned about the apparent contradiciton internal to the ATF opinion especially in the use of the words "originally made" when referring to the handgun. So I might just write them a letter.
Actually, when you remove the stock and replace it with a pistol buffer group, you can legally own and carry it as a pistol. The ATF would like to be advised that it is no longer a SBR and they are supposed to annotate the registry accordingly.
The problem comes in reattaching the stock when you return home. Having re-made the SBR into a pistol, changing it back would legally require you to submit the Form 1 AGAIN, pay the tax AGAIN, and wait until the Form was returned AGAIN.
It doesn't appear that your question includes those steps. Could you do what you are asking without going to jail or losing the firearm? Probably. Would I want to chance it knowing that I can buy a complete lower for less than the tax stamp? Not real likely.
You could always write a letter to the ATF removing the SBR status on the gun (and I always recommend including a copy of your Form 1 or 4 when you do that) and tuck it away to be mailed at the same time your NOK comes to make your bail. Who is to say that the letter didn't get delayed in the mail? Update the letter each time you leave the state and then destroy it when you get home. Just keep in mind that if you ever forget to go through all that, karma may be looking for you.
Having said all of that, I am concerned about the apparent contradiciton internal to the ATF opinion
especially in the use of the words "originally made" when referring to the handgun. So I might just write them a letter.Pretty sure they still postmark mail. This sounds like your classic gun shop tale of a plan.
2/1/2012 7:52:40 PM
Originally Posted By MasterSergeantA:
Actually, when you remove the stock and replace it with a pistol buffer group, you can legally own and carry it as a pistol. The ATF would like to be advised that it is no longer a SBR and they are supposed to annotate the registry accordingly.
The problem comes in reattaching the stock when you return home. Having re-made the SBR into a pistol, changing it back would legally require you to submit the Form 1 AGAIN, pay the tax AGAIN, and wait until the Form was returned AGAIN.
It doesn't appear that your question includes those steps. Could you do what you are asking without going to jail or losing the firearm? Probably. Would I want to chance it knowing that I can buy a complete lower for less than the tax stamp? Not real likely.
You could always write a letter to the ATF removing the SBR status on the gun (and I always recommend including a copy of your Form 1 or 4 when you do that) and tuck it away to be mailed at the same time your NOK comes to make your bail. Who is to say that the letter didn't get delayed in the mail? Update the letter each time you leave the state and then destroy it when you get home. Just keep in mind that if you ever forget to go through all that, karma may be looking for you.
Having said all of that, I am concerned about the apparent contradiciton internal to the ATF opinion especially in the use of the words "originally made" when referring to the handgun. So I might just write them a letter.
Actually you don't have a clue as to what your talking about. Please provide a reference to the ATF rule stating this is legal.Actually, when you remove the stock and replace it with a pistol buffer group, you can legally own and carry it as a pistol. The ATF would like to be advised that it is no longer a SBR and they are supposed to annotate the registry accordingly.
The problem comes in reattaching the stock when you return home. Having re-made the SBR into a pistol, changing it back would legally require you to submit the Form 1 AGAIN, pay the tax AGAIN, and wait until the Form was returned AGAIN.
It doesn't appear that your question includes those steps. Could you do what you are asking without going to jail or losing the firearm? Probably. Would I want to chance it knowing that I can buy a complete lower for less than the tax stamp? Not real likely.
You could always write a letter to the ATF removing the SBR status on the gun (and I always recommend including a copy of your Form 1 or 4 when you do that) and tuck it away to be mailed at the same time your NOK comes to make your bail. Who is to say that the letter didn't get delayed in the mail? Update the letter each time you leave the state and then destroy it when you get home. Just keep in mind that if you ever forget to go through all that, karma may be looking for you.
Having said all of that, I am concerned about the apparent contradiciton internal to the ATF opinion
especially in the use of the words "originally made" when referring to the handgun. So I might just write them a letter.You cannot "remake" a title 2 firearm into a pistol. A pistol is only a pistol when it was originally made as a pistol. It's in the very definition of a pistol. That definition is not the ATF definition, it is the US Congress's definition of a pistol, is codified as such and is not up to interpretation by the ATF or anyone else.
ATF 4-2011 states that you can convert a pistol to a rifle and return it back to it's original pistol configuration based on this definition. So please show the ruling or opinion that allows any other type of firearm to be legally made into a pistol and sold as such.
26 U.S.C. Chapter 53:
Pistol. A weapon originally designed, made, and intended to fire a projectile (bullet) from one or more barrels when held in one hand, and having (a) a chamber(s) as an integral part(s) of, or permanently aligned with, the bore(s); and (b) a short stock designed to be gripped by one hand and at an angle to and extending below the line of the bore(s).
2/2/2012 9:16:11 PM
Originally Posted By iNeXile556:
You cannot "remake" a title 2 firearm into a pistol. A pistol is only a pistol when it was originally made as a pistol. It's in the very definition of a pistol. That definition is not the ATF definition, it is the US Congress's definition of a pistol, is codified as such and is not up to interpretation by the ATF or anyone else.
ATF 4-2011 states that you can convert a pistol to a rifle and return it back to it's original pistol configuration based on this definition. So please show the ruling or opinion that allows any other type of firearm to be legally made into a pistol and sold as such.
You cannot "remake" a title 2 firearm into a pistol. A pistol is only a pistol when it was originally made as a pistol. It's in the very definition of a pistol. That definition is not the ATF definition, it is the US Congress's definition of a pistol, is codified as such and is not up to interpretation by the ATF or anyone else.
ATF 4-2011 states that you can convert a pistol to a rifle and return it back to it's original pistol configuration based on this definition. So please show the ruling or opinion that allows any other type of firearm to be legally made into a pistol and sold as such.
My AR15 pistol started life as a pistol and as such, is engraved "pistol" on the lower from Spikes. It is now waiting for the Form 1.
In this scenario and going by your statement, would this be legal to convert my SBR back to pistol form if I wanted to?
Thats my understanding from all these recent Rulings.
2/2/2012 10:06:11 PM
Originally Posted By nolexforever:
My AR15 pistol started life as a pistol and as such, is engraved "pistol" on the lower from Spikes. It is now waiting for the Form 1.
In this scenario and going by your statement, would this be legal to convert my SBR back to pistol form if I wanted to?
Thats my understanding from all these recent Rulings.
No, Because your SBR will not have started life as a pistol. When you file the form1 you are filling out a application to make a firearm. You are the manufacture that is why you must engrave your (the manufacture's) name and city, state on it just like any other manufacturer. It makes no difference what you make it from, a block of aluminum or a completed firearm, you are making the firearm for the very first time and it is starting it's life as that firearm, not the one you use the parts from.Originally Posted By iNeXile556:
You cannot "remake" a title 2 firearm into a pistol. A pistol is only a pistol when it was originally made as a pistol. It's in the very definition of a pistol. That definition is not the ATF definition, it is the US Congress's definition of a pistol, is codified as such and is not up to interpretation by the ATF or anyone else.
ATF 4-2011 states that you can convert a pistol to a rifle and return it back to it's original pistol configuration based on this definition. So please show the ruling or opinion that allows any other type of firearm to be legally made into a pistol and sold as such.
You cannot "remake" a title 2 firearm into a pistol. A pistol is only a pistol when it was originally made as a pistol. It's in the very definition of a pistol. That definition is not the ATF definition, it is the US Congress's definition of a pistol, is codified as such and is not up to interpretation by the ATF or anyone else.
ATF 4-2011 states that you can convert a pistol to a rifle and return it back to it's original pistol configuration based on this definition. So please show the ruling or opinion that allows any other type of firearm to be legally made into a pistol and sold as such.
My AR15 pistol started life as a pistol and as such, is engraved "pistol" on the lower from Spikes. It is now waiting for the Form 1.
In this scenario and going by your statement, would this be legal to convert my SBR back to pistol form if I wanted to?
Thats my understanding from all these recent Rulings.
When you put a long barrel and stock on a pistol you are not making a rifle, you are converting it, temporarily, and you can return it to its original configuration.
When you put a VFG on a pistol greater than 26" in overall length you are not making a firearm, you are converting a pistol into simple title1 firearm.
When you make a title2 firearm you are "making" a firearm.
2/18/2012 7:49:40 PM
Thanks for the input.
I first heard what I hoped to hear ... then basically the opposite. We must be discussing Federal Bureaucracy!
I guess before I bother to get the SBR stamp I'd better do more research.
I had in mind to come up with a very easily removable folding stock for my KelTec PLR-16. In-state I'd have my SBR. Traveling, I'd have my pistol the way KelTec manufactured it. But ... what sounds sensible to us may not to BATFE.
I first heard what I hoped to hear ... then basically the opposite. We must be discussing Federal Bureaucracy!
I guess before I bother to get the SBR stamp I'd better do more research.
I had in mind to come up with a very easily removable folding stock for my KelTec PLR-16. In-state I'd have my SBR. Traveling, I'd have my pistol the way KelTec manufactured it. But ... what sounds sensible to us may not to BATFE.
2/20/2012 8:24:20 AM
Just a friendly IMHO to all..... Don't play word games with the BATF
OP - as was said before - building another pistol lower isn't that expensive.
2/26/2012 11:01:36 AM
Does all this mean that I can put a butstock on my AR pistol and a vertical forgrip or do I also have to change the barrel length?
2/27/2012 2:39:57 PM
With BATFE approval for creation of an SBR (I believe this is Form 1), the buttstock and/or VFG are legal. Without that approval, neither is legal.
Once you're approved for an SBR and "manufacture" the thing by adding one of those accessories, you may have it within your state w/o further hassle. If you want to take it across state lines, you need specific approval.
I would like to be able to take my weapon with me across state lines w/o waiting for gov't approval. Since my pistol is currently just a legal pistol, I can do that. If I do a Form 1 and make an SBR ... it would seem sensible that I could return it to its original configuration for travel w/o approval. But sense and bureaucracy do not always intersect.
Once you're approved for an SBR and "manufacture" the thing by adding one of those accessories, you may have it within your state w/o further hassle. If you want to take it across state lines, you need specific approval.
I would like to be able to take my weapon with me across state lines w/o waiting for gov't approval. Since my pistol is currently just a legal pistol, I can do that. If I do a Form 1 and make an SBR ... it would seem sensible that I could return it to its original configuration for travel w/o approval. But sense and bureaucracy do not always intersect.
2/27/2012 2:54:43 PM
Originally Posted By DanielWilson:
With BATFE approval for creation of an SBR (I believe this is Form 1), the buttstock and/or VFG are legal. Without that approval, neither is legal.
Once you're approved for an SBR and "manufacture" the thing by adding one of those accessories, you may have it within your state w/o further hassle. If you want to take it across state lines, you need specific approval.
I would like to be able to take my weapon with me across state lines w/o waiting for gov't approval. Since my pistol is currently just a legal pistol, I can do that. If I do a Form 1 and make an SBR ... it would seem sensible that I could return it to its original configuration for travel w/o approval. But sense and bureaucracy do not always intersect.
With BATFE approval for creation of an SBR (I believe this is Form 1), the buttstock and/or VFG are legal. Without that approval, neither is legal.
Once you're approved for an SBR and "manufacture" the thing by adding one of those accessories, you may have it within your state w/o further hassle. If you want to take it across state lines, you need specific approval.
I would like to be able to take my weapon with me across state lines w/o waiting for gov't approval. Since my pistol is currently just a legal pistol, I can do that. If I do a Form 1 and make an SBR ... it would seem sensible that I could return it to its original configuration for travel w/o approval. But sense and bureaucracy do not always intersect.
the problem is that once you Form 1 the pistol into a "short barreled RIFLE", it is no longer a pistol, and it is viewed as a newly created firearm (as has already been stated).
lowers are cheap, buy a second lower to Form 1 into an SBR, keep the pistol lower for when you're traveling interstate, and leave the SBR lower at home. this way you're legal all the time without an approved 5320.20
as for the 5320.20's go, you can fill them out in advance and the duration can be up to one year per form. there are many folks that do this as part of emergency preps, hunting plans, or just because their favorite range is 5 minutes across a state border. all you need is a destination address which can be someone's house or a range you frequent.
2/27/2012 4:07:52 PM
It would be cheaper to pick a solution that isn't questionable. 
2/27/2012 4:29:38 PM
The responses in this thread are more complex than they need to be.
Once a stock is added to an AR15 pistol, it is considered a rifle. Removing the stock does NOT make it go back to being classified as a pistol.
That is why you have to build an AR pistol from a stripped lower that has never been assembled as a rifle.
Once it has a stock and a barrel mated to it and it is considered a "rifle" (even a short barrelled RIFLE), it is always considered a rifle.
Taking the stock off of it, once it is assembled as an SBR, doesn't change a thing. It will still be considered an SBR even without the stock. You could always put a 16' barrelled upper on it, and it would be removed from the purview of the NFA branch. That's about it.
Once a stock is added to an AR15 pistol, it is considered a rifle. Removing the stock does NOT make it go back to being classified as a pistol.
That is why you have to build an AR pistol from a stripped lower that has never been assembled as a rifle.
Once it has a stock and a barrel mated to it and it is considered a "rifle" (even a short barrelled RIFLE), it is always considered a rifle.
Taking the stock off of it, once it is assembled as an SBR, doesn't change a thing. It will still be considered an SBR even without the stock. You could always put a 16' barrelled upper on it, and it would be removed from the purview of the NFA branch. That's about it.
2/27/2012 7:00:47 PM
Originally Posted By Just_Tom:
The responses in this thread are more complex than they need to be.
Once a stock is added to an AR15 pistol, it is considered a rifle. Removing the stock does NOT make it go back to being classified as a pistol.
That is why you have to build an AR pistol from a stripped lower that has never been assembled as a rifle.
Once it has a stock and a barrel mated to it and it is considered a "rifle" (even a short barrelled RIFLE), it is always considered a rifle.
Taking the stock off of it, once it is assembled as an SBR, doesn't change a thing. It will still be considered an SBR even without the stock. You could always put a 16' barrelled upper on it, and it would be removed from the purview of the NFA branch. That's about it.
The responses in this thread are more complex than they need to be.
Once a stock is added to an AR15 pistol, it is considered a rifle. Removing the stock does NOT make it go back to being classified as a pistol.
That is why you have to build an AR pistol from a stripped lower that has never been assembled as a rifle.
Once it has a stock and a barrel mated to it and it is considered a "rifle" (even a short barrelled RIFLE), it is always considered a rifle.
Taking the stock off of it, once it is assembled as an SBR, doesn't change a thing. It will still be considered an SBR even without the stock. You could always put a 16' barrelled upper on it, and it would be removed from the purview of the NFA branch. That's about it.
Actually you can go from a pistol to a rifle and back to a pistol provided the firearm started life as a pistol, see ATF ruling 2011-4.
The problem here is that a SBR does not start as a pistol. It is made for the first time as a SBR on form 1 and so starts it's life as a SBR.
2/27/2012 7:15:37 PM
Originally Posted By iNeXile556:
Actually you can go from a pistol to a rifle and back to a pistol provided the firearm started life as a pistol, see ATF ruling 2011-4.
The problem here is that a SBR does not start as a pistol. It is made for the first time as a SBR on form 1 and so starts it's life as a SBR.
Originally Posted By Just_Tom:
The responses in this thread are more complex than they need to be.
Once a stock is added to an AR15 pistol, it is considered a rifle. Removing the stock does NOT make it go back to being classified as a pistol.
That is why you have to build an AR pistol from a stripped lower that has never been assembled as a rifle.
Once it has a stock and a barrel mated to it and it is considered a "rifle" (even a short barrelled RIFLE), it is always considered a rifle.
Taking the stock off of it, once it is assembled as an SBR, doesn't change a thing. It will still be considered an SBR even without the stock. You could always put a 16' barrelled upper on it, and it would be removed from the purview of the NFA branch. That's about it.
The responses in this thread are more complex than they need to be.
Once a stock is added to an AR15 pistol, it is considered a rifle. Removing the stock does NOT make it go back to being classified as a pistol.
That is why you have to build an AR pistol from a stripped lower that has never been assembled as a rifle.
Once it has a stock and a barrel mated to it and it is considered a "rifle" (even a short barrelled RIFLE), it is always considered a rifle.
Taking the stock off of it, once it is assembled as an SBR, doesn't change a thing. It will still be considered an SBR even without the stock. You could always put a 16' barrelled upper on it, and it would be removed from the purview of the NFA branch. That's about it.
Actually you can go from a pistol to a rifle and back to a pistol provided the firearm started life as a pistol, see ATF ruling 2011-4.
The problem here is that a SBR does not start as a pistol. It is made for the first time as a SBR on form 1 and so starts it's life as a SBR.
What if you build your AR pistol yourself and then SBR it?
A lot of people do that. Not all SBR's start life as an SBR...Many people make a pistol INTO an SBR.
Item (b) in the first passage of the ruling that you linked clearly says: (b) convert a complete weapon into such an NFA firearm.
2/27/2012 8:14:03 PM
Originally Posted By Just_Tom:
What if you build your AR pistol yourself and then SBR it?
A lot of people do that. Not all SBR's start life as an SBR...Many people make a pistol INTO an SBR.
Item (b) in the first passage of the ruling that you linked clearly says: (b) convert a complete weapon into such an NFA firearm.
Originally Posted By iNeXile556:
Actually you can go from a pistol to a rifle and back to a pistol provided the firearm started life as a pistol, see ATF ruling 2011-4.
The problem here is that a SBR does not start as a pistol. It is made for the first time as a SBR on form 1 and so starts it's life as a SBR.
Originally Posted By Just_Tom:
The responses in this thread are more complex than they need to be.
Once a stock is added to an AR15 pistol, it is considered a rifle. Removing the stock does NOT make it go back to being classified as a pistol.
That is why you have to build an AR pistol from a stripped lower that has never been assembled as a rifle.
Once it has a stock and a barrel mated to it and it is considered a "rifle" (even a short barrelled RIFLE), it is always considered a rifle.
Taking the stock off of it, once it is assembled as an SBR, doesn't change a thing. It will still be considered an SBR even without the stock. You could always put a 16' barrelled upper on it, and it would be removed from the purview of the NFA branch. That's about it.
The responses in this thread are more complex than they need to be.
Once a stock is added to an AR15 pistol, it is considered a rifle. Removing the stock does NOT make it go back to being classified as a pistol.
That is why you have to build an AR pistol from a stripped lower that has never been assembled as a rifle.
Once it has a stock and a barrel mated to it and it is considered a "rifle" (even a short barrelled RIFLE), it is always considered a rifle.
Taking the stock off of it, once it is assembled as an SBR, doesn't change a thing. It will still be considered an SBR even without the stock. You could always put a 16' barrelled upper on it, and it would be removed from the purview of the NFA branch. That's about it.
Actually you can go from a pistol to a rifle and back to a pistol provided the firearm started life as a pistol, see ATF ruling 2011-4.
The problem here is that a SBR does not start as a pistol. It is made for the first time as a SBR on form 1 and so starts it's life as a SBR.
What if you build your AR pistol yourself and then SBR it?
A lot of people do that. Not all SBR's start life as an SBR...Many people make a pistol INTO an SBR.
Item (b) in the first passage of the ruling that you linked clearly says: (b) convert a complete weapon into such an NFA firearm.
A very simple way to be sure is to write the ATF and ask them. Their opinion is the only one that matters.
