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Eta: Putting the 20" upper on the pistol lower I believe would change the classification from pistol to firearm. Perfectly legal and still not a rifle but technically not a pistol.
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Can you show what that's based on? I can't find anything stating that.
I've looked in the USC under Definitions;
"
26 U.S.C. United States Code, 2010 EditionTitle 26 - INTERNAL REVENUE CODESubtitle E - Alcohol, Tobacco, and Certain Other Excise TaxesCHAPTER 53 - MACHINE GUNS, DESTRUCTIVE DEVICES, AND CERTAIN OTHER FIREARMSSubchapter B - General Provisions and ExemptionsPART I - GENERAL PROVISIONSSec. 5845 - DefinitionsFrom the U.S. Government Printing Office, www.gpo.gov§5845. Definitions
For the purpose of this chapter—
(a) Firearm
The term "firearm” means (1) a shotgun having a
barrel or barrels of less than 18 inches in length; (2) a weapon made
from a shotgun if such weapon as modified has an overall length of less
than 26 inches or a barrel or barrels of less than 18 inches in length;
(3) a rifle having a barrel or barrels of less than 16 inches in length;
(4) a weapon made from a rifle if such weapon as modified has an
overall length of less than 26 inches or a barrel or barrels of less
than 16 inches in length; (5) any other weapon, as defined in subsection
(e); (6) a machinegun; (7) any silencer (as defined in section 921 of
title 18, United States Code); and (8) a destructive device. The term
"firearm” shall not include an antique firearm or any device (other than
a machinegun or destructive device) which, although designed as a
weapon, the Secretary finds by reason of the date of its manufacture,
value, design, and other characteristics is primarily a collector's item
and is not likely to be used as a weapon."
I also found an ATF letter that looks to me as though overall length of concealable firearms isn't even defined;
(Question #4)
This response to Franklin Armory seems to say that a vertical forward pistol grip is what would change the classification, rather than the overall length.
That's all I've found so far...