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Rifles, Reloading, Optics, Equipment
Suppressors
ATF Diversified Machine Letter
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<blockquote data-quote="QuietTexan" data-source="post: 2399387" data-attributes="member: 116181"><p>I agree, the ATF firebombed the entire customer records list they obtained with a scare letter. Field Office SAC is running his investigation and isn't going to waste time trying to reconcile the customer list to the registry because there are too many variables. Too many orders for spare parts, too many orders for multiple tubes, they don't want to mess with that. They want you to prove up you have one stamped Form 1 per suppressor. Read 18 USC 1001, that's why they're asking you to represent the info to them - charge stacking.</p><p></p><p>The "special occupational taxpayer" SOT language reads like they're assuming the worst-case scenario of you purchased what they define as complete silencers without an FFL 01/02, Class 3 SOT and Form 3 transfer, or that you purchased silencer parts and then manufactured silencers without an FFL 07/10, Class 2 SOT, and filing a Form 2. At that point they'd probably say you'd have to abandon the Form 1 and turn the can in or spend lots more money defending a few hundred bucks and a tax stamp.</p><p></p><p>Hopefully you can provide the Form 1 to show registration concurrent with manufacture/possession and intent to comply, then make a good faith argument that you were unaware of the recategorization of the parts until the letter arrived.</p><p></p><p>Found this re: this exact letter:</p><p>[URL unfurl="true"]https://www.thetruthaboutguns.com/atf-just-fedexd-warning-letters-to-thousands-of-silencer-part-consumers/[/URL]</p></blockquote><p></p>
[QUOTE="QuietTexan, post: 2399387, member: 116181"] I agree, the ATF firebombed the entire customer records list they obtained with a scare letter. Field Office SAC is running his investigation and isn't going to waste time trying to reconcile the customer list to the registry because there are too many variables. Too many orders for spare parts, too many orders for multiple tubes, they don't want to mess with that. They want you to prove up you have one stamped Form 1 per suppressor. Read 18 USC 1001, that's why they're asking you to represent the info to them - charge stacking. The "special occupational taxpayer" SOT language reads like they're assuming the worst-case scenario of you purchased what they define as complete silencers without an FFL 01/02, Class 3 SOT and Form 3 transfer, or that you purchased silencer parts and then manufactured silencers without an FFL 07/10, Class 2 SOT, and filing a Form 2. At that point they'd probably say you'd have to abandon the Form 1 and turn the can in or spend lots more money defending a few hundred bucks and a tax stamp. Hopefully you can provide the Form 1 to show registration concurrent with manufacture/possession and intent to comply, then make a good faith argument that you were unaware of the recategorization of the parts until the letter arrived. Found this re: this exact letter: [URL unfurl="true"]https://www.thetruthaboutguns.com/atf-just-fedexd-warning-letters-to-thousands-of-silencer-part-consumers/[/URL] [/QUOTE]
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ATF Diversified Machine Letter
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