Circuits:
What I think the ATF does in the case you mention about an M-16 bolt carrier and hammer is that they intentionally make the weapon malfunction by using soft pistol primers and remove the disconnector, therefore allowing the hammer to follow the carrier and maybe fire the next round. So if they can make your rifle malfunction, it is an unregistered machine gun. I've seem more reliable slam fires with improperly seated primers than this.
I agree with your no official ruling statement and I wish I could find a better reporting of the case, United States v. Corcoran, where Judge Donald E. Zeigler said, in explaining why he was dismissing 6 counts of possessing or transferring unregistered machine guns:
[i]"The AR-15's in this case were transferred by defendant without automatic sears. The essence of due process of law requires that the government make clear that conduct which constitutes a crime. Here, the ATF ruled on November 1, 1981, that an AR-15 with M-16 internal components already installed, will convert to a machine gun with the single addition of an automatic sear. It is inescapable that without the automatic
sear, the AR15 with M-16 components parts is not a machine gun and need not be registered. If it did constitute a machine gun, because it may fire more than one round with a single function of the trigger, the agency was required to make that clear in the Federal Firearms Regulations, especially in light of ATF Ruling 81-4 effective November 1, 1981.
"In short, once Ruling 81-4 was made and published, the agency was required to supplement that ruling to make clear that conduct which was once legal, or at least arguably legal, was now prohibited.
"In addition, the arguments that the agency did change its policy, in letters to interested citizens after November 1, 1981, is without merit. The change must be published in the same manner that the original ruling was published; otherwise citizens who relied on Ruling 81-4 but did not inquire of the government could be prosecuted for a crime while other citizens could not.[/i]"
[b]United States v. Corcoran[/b], Criminal No. 88-11 (W.D. Pa. April 5, 1988), transcript, pages 39-40
(quoted from [url=http://www-2.cs.cmu.edu/afs/cs/user/wbardwel/public/nfalist/ar_15_auto_sear_faq.txt] NFA and other gun law related info and cases: Pre-81 AR-15 Drop-in Auto Sears[/url])
All I know is that this was a federal case in Pennsylvania in 1988, so this was prior to a few amendments to the NFA and I don't know if it is still or ever was controling law.
Cheers, Otto