DEPARTMENT OF THE TREASURY
             Bureau of Alcohol, Tobacco and Firearms
                     Office of Chief Counsel
                 Room 701, 1114 Commerce Street
                       Dallas, Texas 75242


                        February 6, 1987          SW:RC:REW
                                                  6773

MEMORANDUM TO:      Resident Agent in Charge
                    Denver, Colorado Post of Duty

FROM:               Regional Counsel

SUBJECT:            Leon Greenwald

Reference is made to your telephone inquiry of February 5, 1987,
regarding certain National Firearms Act firearms registered to Leon
Greenwald.  You telephonically indicated that Mr. Greenwald was
convicted of a felony offense.  The federal district court that
tried Mr. Greenwald issued an order for all firearms in Mr.
Greenwald's possession to be transferred to his attorneys for
proper disposition in order to help defray attorney expenses.  You
inquired as to whether the attorneys could hold the National
Firearms Act firearms registered to Mr. Greenwald as his attorneys
and whether they could act as middlemen in arranging the transfer
of such firearms to third party purchasers.

As provided in 26 U.S.C. section 5861(d), it is unlawful for any
person to receive or possess a firearm which is not registered to
him in the National Firearms Registration and Transfer Record. 
However, where a court orders the registered firearms of a
convicted person to be held by such person's attorney during the
time frame in which a purchaser is sought for such firearms, such
possession would not place the possessor in violation of 26 U.S.C.
section 5861(d).  As the attorneys are in temporary possession of
such firearms pursuant to the court order, the National Firearms
Act Branch in Bureau Headquarters should be furnished a copy of the
court order to reflect such temporary possession in the National
Firearms Registration and Transfer Record.  In addition, we believe
the attorneys of

                              - 2 -

Resident Agent in Charge
Denver, Colorado Post of Duty


Mr. Greenwald may act as his agent in procuring a purchaser for
such firearms.  The transfer application and transfer tax would
have to be filed and paid by Mr. Greenwald in accordance to 26
U.S.C. sections 5811 and 5812.

If we can be of further assistance, please advise.

                            [signed]

                         Bobby S. Tyler