DEPARTMENT OF THE TREASURY
                Bureau of Alcohol, Tobacco and Firearms
                         Washington, DC 20226

                                                           E:CE:FT:CHB
                                                           3311

                              MAR 24 1997

[Name]
[Address]

Dear  :

This refers to your letter of February 16, 1997, in which you ask
about assembling a machinegun using a registered Sten receiver and
a Sterling parts set.

A Sten gun receiver is a firearm and a machinegun as defined in 26
U.S.C. section 5845(b) of the National Firearms Act (NFA).  It is
unlawful for anyone to make or possess a machinegun which is not
registered in accordance with the provisions of the NFA.  It is
unlawful for individuals to transfer or possess a machinegun which
was not lawfully possessed prior to May 19, 1986, as provided in 18
U.S.C. section 922(o).

You ask about having a qualified manufacturer assemble a functional
machinegun using registered Sten receiver and a Sterling
submachinegun kit.  Such assembly may be accomplished without
creating a new machinegun if the following guidelines are followed:

      1.   The entire Sten gun receiver should be used.

      2.   The Sterling barrel shroud from the parts set should be
           welded to the front of the Sten receiver.

      3.   The magazine well, pistol grip/trigger housing assembly,
           and ejection port deflector may be removed from the
           Sterling parts set and then installed directly onto the
           Sten receiver using the original Sten magazine port and
           ejection port.

                                 - 2 -

      4.   Weld the original rear end of the Sterling receiver onto
           the rear end of the Sten receiver.

      5.   Use a Sten gun bolt or alter the bolt handle position on
           the Sterling bolt to be compatible with the bolt handle
           slot in the Sten receiver.

The assembly and possession of a firearm as described above, using
a registered Sten gun receiver and a Sterling parts set as
described above would not be violation of the provisions of 18
U.S.C. section 922(o).  The serial number and other required
identification of the machinegun receiver must not be obliterated,
removed, changed or altered (26 U.S.C. section 5861(g)).  After the
alterations are performed, notification must be made to the
National Firearms Act Branch at ATF Headquarters reflecting the
changes made to the dimensions and description of the registered
firearm.

We trust that the foregoing has been responsive to your inquiry. 
If you have further questions concerning this matter, please
contact us.


                           Sincerely yours,

                               [signed]
                          Edward M. Owen, Jr.
                  Chief, Firearms Enforcement Officer