DEPARTMENT OF THE TREASURY
             Bureau of Alcohol, Tobacco and Firearms
                     Washington, D.C. 20226

                           NOV -5 1997            E:SD:FTB:RDC
                                                  3311

Dear Mr. :

This refers to your letter of October 20, 1997, in which you
inquire about the legality of assembling a Daewoo DR200 5.56mm
semiautomatic with a fixed shoulder stock and separate pistol grip.

Please refer to the enclosed pamphlets entitled "Assembly of
Semiautomatic Rifles and Shotguns from Imported Parts under 18
U.S.C. Chapter 44" and "Semiautomatic Assault Weapons and Large
Capacity Ammunition Feeding Devices under 18 U.S.C. Chapter 44."

Title 27 Code of Federal Regulations (CFR) Section 178.39 states
that no person shall assemble a semiautomatic rifle or any shotgun
using more than 10 of the imported parts listed below if the
assembled firearm is prohibited from importation under section 925
(d) (3).  For the purposes of this section, the term "imported
parts" are:

(1)  Frames receivers, receiver castings, forgings, or stampings
(2)  Barrels
(3)  Barrel Extensions
(4)  Mounting blocks (trunnions)
(5)  Muzzle attachments
(6)  Bolts
(7)  Bolt carriers
(8)  Operating rods
(9)  Gas pistons
(10) Trigger housings
(11) Triggers
(12) Hammers
                              - 2 -


(13) Sears
(14) Disconnectors
(15) Buttstocks
(16) Pistol grips
(17) Forearms, handguards
(18) Magazine bodies
(19) Followers
(20) Floorplates

For the purposes of 27 CFR Section 178.39(c), the Daewoo DR 200
semiautomatic rifle contains items numbered (1), (2), (3), (5),
(6), (7), (8), (9), (11), (12), (14), (15), and (17).  Exchanging
the thumbhole stock with a fixed shoulder stock and separate pistol
grip would be in violation of 18 U.S.C. Section 922(r) if the
firearm was assembled using more than 10 of the above listed
imported parts.  It would also constitute the making of an
semiautomatic assault weapon in violation of 18 U.S.C. Section
922(v)(1).

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


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