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Ron,
Your interpretation is the same as mine. I feel this is one area where the ATF is totally confused. The "upper" receiver is the part that should be the controlled item, but ATF doesn't see it that way... they look at the lower frame as the controlled item. DUH!
There is no much consistency in ATF rulings or even opinions... The Ruger .22 caliber autoloaders for example... the ATF rightly thinks the round upper receiver is the controlled part, and the grip frame is not controlled... totally backwards from a Luger and the the top half of the Ruger CAN'T fire a round without the frame!
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