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You are registering the lower (it is the firearm/serial #) as the SBR. SBR is allowed to have "a barrel shorter than 16 inch"... You do not need to register each barrel. I have 1 SBR AR-15, and 3 working uppers currently, in 2 calibers.
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OK i'll give you that a SBR is any barrel length under 16 inches.....but just because the upper is easily swapped out, compared to other weapons where the barrel can't, how does that make it legal to have the paperwork say one thing, and the rifle another? I understand that the serial number will be the same....but the length and caliber won't jive with the paperwork.
can you cite a ATF reg that states this is legal?
the reason I ask, I don't think they put a block on the form 1 that states what the barrel length, and caliber is, just for shits and giggles. if the serial number is registed to have a certain barrel length and for a certain caliber....I don't believe they will allow a varance for another length or caliber on the same form. but I could be wrong.....if you can prove without a shadow of a doubt, that this swapping out different lengths and calibers is legal, despite what the paperwork for that serial number is, then I will bow to your knowledge.