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

                         NOV 25 1997             F:SD:FTB:GKD
                                                 3311


Dear Mr. :

This refers to your letter of November 6, 1997, requesting
information on the manufacture of a firearm to be classified as an
"any other weapon," as that term is defined in the National
Firearms Act (NFA).

You describe the proposed firearm as being manufactured using an
AR15 type lower receiver that has never been assembled as a
complete firearm and installing a "pistol length barrel," a rear
pistol grip, a vertical foregrip, shrouded barrel and a flash
hider.  This firearm would utilize a detachable magazine installed
outside the pistol grip.

A firearm manufactured from the described components and in the
described manner would not be a pistol as defined in either Title
27, Code of Federal Regulations (CFR), Part 178 or 179, nor would
it be classified as a rifle or shotgun, not being designed to be
held and fired from the shoulder.  Further, it is not classified as
a semiautomatic assault weapon as defined in Title 18 U.S.C.,
Chapter 44, Section 921(a)(30), hence it is not subject to the
prohibition on the manufacture, transfer or possession of
semiautomatic assault weapons as provided in Title 18 U.S.C.,
Chapter 44, Section 922(v).

The Bureau of Alcohol, Tobacco and Firearms (ATF) has previously
held that a firearm of the type described in your letter is
classified as an "any other weapon" and is subject to all of the
provisions of the NFA.  Such a firearm could legally be
manufactured and transferred by a Class II manufacturer.  An
unlicensed individual could manufacture such a firearm by first
submitting an AT Form 1, APPLICATION TO MAKE AND REGISTER A
FIREARM, to ATF.  Upon receipt of the approved form, the individual
could then proceed to manufacture the firearm.

                              - 2 -

Mr. 

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