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

                                                           E:CE:FT:MJC
                                                           3311

                              May 12 1997

[Name]
[Address]

Dear  :

This refers to your letter of March 15, 1997, in which you request
the legality of owning an M/11 380 to 9mm thread adaptor.  You have
enclosed a copy of an advertisement with a picture of the device.

As defined in Title 18 U.S.C., Chapter 44, Section 921(a)(24) of
the Gun Control Act of 1968 (GCA) and Title 26 U.S.C., Chapter 53,
Section 5845 (a)(7) of the National Firearms Act (NFA), the term
"firearm silencer" and "firearm muffler" means any device for
silencing, muffling, or diminishing the report of a portable
firearm, including any combination of parts, designed or
redesigned, and intended for use in assembling or fabricating a
firearm silencer or firearm muffler, and any part intended only for
use in such assembly or fabrication.

It is unlawful for anyone to possess an NFA firearm which is not
registered in accordance with the provisions of the NFA.

A thread adaptor is a device that mounts on the muzzle of a firearm
and permits certain muzzle attachments or accessories, with
different style threads, to be affixed to the muzzle of the
firearm.

Based on the information provided and our research, the thread
adaptor described in the advertisement is not a part intended only
for the assembly or fabrication of a firearm silencer or muffler.

We trust the foregoing has been responsive to your inquiry.  If we
may be of any further assistance, please contact us.


                           Sincerely yours,

                               [signed]
                          Edward M. Owen, Jr.
                   Chief, Firearms Technology Branch