Revenue Ruling 57-227

       Only those firearms covered by section 5848 of the Internal
     Revenue Code of 1954 which have been deactivated in the manner
     prescribed in Revenue Ruling 55-590, C.B. 1955-2, 483, under
     the supervision of an investigator of the Alcohol and Tobacco
     Tax Division, may be considered in the category of "DEWAT." 
     Notwithstanding its operating condition, any firearm covered
     by such section which has not been deactivated in the
     prescribed manner under the supervision of such officer comes
     within the purview of Chapter 53 of the Code inasmuch a the
     exemption afforded "unserviceable" firearms is conditional and
     applicable only in respect to the transfer tax imposed under
     section 5811(a) of the Code.

     The Internal Revenue Service emphasizes the distinction
between an "unserviceable" firearm and a "DEWAT" as defined in
Revenue Ruling 55-590, C.B. 1955-2, 483, for purposes of Chapter 53
of the Internal Revenue Code of 1954, and announces that such
distinction will be enforced in order to avoid abuses of the ruling
in respect of DEWATS.
     The minimum requirements for the process of transforming a
firearm into a DEWAT were established with the assistance of
recognized ordnance experts, and the Internal Revenue Service has
consistently held that the deactivation must be witnessed by the
investigator who certifies as to the condition of the DEWAT.  To
insure that the minimum requirements would be met, investigators of
the Alcohol and Tobacco Tax Division were instructed to make the
necessary arrangements to have firearms deactivated by experienced
welders under their supervision.  Such deactivation has ordinarily
been accomplished at no expense to the individual owners of the
firearms.  The procedure was adopted, and has been continued, (1)
since experience has shown that improper welding increases the
possibility of reactivating a DEWAT and, (2) to eliminate any
possibility of substitute brazing, soldering, or other process to
simulate steel welding in "deactivating" firearms.
     It is the position of the Internal Revenue Service that only
such firearms covered by section 5848 of the Internal Revenue Code
of 1954 which have been deactivated in the prescribed manner under
the supervision of Alcohol and Tobacco Tax investigators may be
considered in the category of DEWATS.  Any firearms which have not
been deactivated in the prescribed manner under the supervision of
such officers come within the purview of Chapter 53 of the Internal
Revenue Code of 1954 notwithstanding their operating condition,
inasmuch as the exemption afforded "unserviceable" firearms is
conditional and applicable only in respect to the transfer tax
imposed under section 5811(a) of the Code.
     A "DEWAT" and an "unserviceable" firearm under Chapter 53 of
the Code are both firearms under the Federal Firearms Act, 15
U.S.C. 901-909, and, accordingly, are subject to the applicable
provisions of the Federal Firearms Act and the regulations issued
pursuant thereto since "any part or parts" of a weapon is a
"firearm" as defined therein.