BUREAU OF ALCOHOL, TOBACCO AND FIREARMS
                   DEPARTMENT OF THE TREASURY

                                                  901040:GS
                                                  5320/990500

                           10 JAN 2000

Dear Mr. Bardwell:

This is in response to your letter of November 11, 1999, requesting
information from the Bureau of Alcohol, Tobacco and Firearms (ATF)
about transferring a "post-1986" machinegun from a government
agency to a dealer.  You advised us that you were told that no
"demo" letter is required for this transfer.

In accordance with Title 27, Code of Federal Regulations, section
179.105(d), ATF will consider applications to transfer and register
machineguns manufactured or imported on or after May 19, 1986, to
qualified dealers, if the following information is documented and
submitted to the National Firearms Act Branch with the ATF Form 5:

     (1)  A list of the government customers who are expected to
          require a demonstration of the weapon.

     (2)  Information concerning the availability of the machinegun
          related to subsequent orders.

     (3)  Letters from government entities expressing their need
          for a particular model machinegun or their interest in
          the demonstration of a particular weapon.

                              - 2 -

Mr.

Additionally, if you want to transfer more than one machinegun of
a particular model, please include in writing in the application
package, the justification for transferring the appropriate number
of samples.

The transfer of a "post-1986" machinegun, to a qualified Federal
firearms licensee is subject to the above provisions, regardless of
the transferor.

Should additional information be needed, please contact ATF
Specialist Gary Schaible at (202) 927-8330.

                        Sincerely yours,



                         Kent M. Cousins
               Chief, National Firearms Act Branch