DEPARTMENT OF THE TREASURY 
            BUREAU OF ALCOHOL, TOBACCO AND FIREARMS 
                     WASHINGTON, D.C. 20226

                           AUG 05 1997

Dear :                                       E:RE:FN:GS
                                             179.11/97-1858


This is in response to your letter of March 25, 1997, regarding a
"suppressed machinegun" registered to your client. You advise that
the machinegun is equipped with an integral silencer and there is
no registration document for the silencer, but the silencer is
removable from the machinegun.

We consider the combination of a machinegun and silencer to be one
unit subject to registration when the silencer is integral to the
machinegun, such as when it is permanently affixed to the
machinegun (not just to the barrel). A removable silencer is a
separate unit, which requires registration.

An existing, unregistered silencer may not be registered by your
client. In order for your client to continue to possess the
silencer, it must be permanently affixed to the machinegun.

We apologize for the delay in responding to your request. Should
any additional information be needed, please contact us at (202)
927-8330.

                        Sincerely yours,


                        Nereida W. Levine
               Chief, National Firearms Act Branch