M*CARBO Brotherhood

Permission Granted, we are a go... repeat we are a go

The parable of Elle:
O’ she walked a great distance and sat with the patience of a saint her diligence has finally bore fruit as the powers on high have looked favourably upon her for the almighty ATF sent for a sign (letter) to notify her of her worthiness and accepted her gift (Highway robbery) of six hundred dollars (plus photos and finger prints and other ancillary costs) and has granted her permission to complete her quest.

She exclaimed with much relief and forced gratitude.

“Praise Jesus praise Allah praise Krishna and Vishnu praise all the god(s) great and small Hail Satan & Bob. Thank you thank you thank you dear sweet ATF… thank you.
(Long pause)
Well that was fun, I’m never doing this again. (Looks at mountain of receipts for build)
how am I going to explain how much I spent to my girlfriend. “

So yeah paperwork is all in, I’m heading to get the tube to my suppressor laser engraved along with the lower receiver. Everything is finally complete.
-Was it worth it, meh… that’s to be seen.
-Will I ever do it again, Oh heck’s no… nope this is it I’m done.
-What’s next next? I’m gonna wait and recover than purchase a .22 upper receiver
-Will I go select fire or with a binary trigger. Absolutely not, as my girlfriend will attest my finger is plenty fast enough and I spent the money buying a precise trigger with a clean and light break, precision over volume.
-What is the intended use, hunting. I ordered 5 round mags and a piston upper a couple days ago so I have the ability to pull the rod turn off the gas and run as a manually operated SBR.
While I have a plethora of ammunition I bought 100 rounds of Barnes VOR-TX for hunting.
-Why a suppressor? Well if your in for a penny your in for a pound… so might as well
-Did I build it all myself? Yes, yes I did. Everything you see here was carefully selected for purpose and Aesthetic value along with value.
-Whats with the PMR? that’s next. Going to order the trigger, feed ramp, Mag catch from M*CARBO
-aesthetics? The colour scheme you see will be also on the PMR, i hope to truly hand at Cerokot and stippling, yes I’ll be stippling and Cerokoting the mags and lower and dying Kevlar Cord I bought to wrap the handguard with. Stay tuned for updates.
-Is there anything you can’t do. Yes, but I’m still working on time travel and eventually I’ll make a perfect soufflé.

Build list:
-Lower receiver: James Madison Tactical Polymer 80 colour FDE
-trigger group: James Madison Tactical Black Ops (reworked and polished)
-Grips: BCM Gunfighter MOD 3 colour FDE
-Upper Receiver: Gibbz Arms G4 Non Reciprocating Side Charging Upper Receiver
-Barrel: Tactical Kinetics 8.5 inch 300 Blackout Pistol Length 1/7 Twist 4150 CMV Melonite Finish
-Bolt Carrier Group: PSA Nitride BCG
(FullAuto)
-Adams Arms Gas Piston Conversion Kit
(On order)
-Sights: Diamondhead USA D-45 Diamond Front and Rear Combat Sights with Integrated Sighting System,
-Optics: Firefield Impulse 1x22 Red/Green Dot
(Optics will be changed when bank account recovers, looking for suggestions)
-Suppresssor was sourced using a parts kit from Solvent Trap Dirrect. Note you will have to do a lot make a solvent trap into a functioning can starting with an approved Form 1 In addition to possessing the skills and machinery to convert unfinished cups into proper clip and port the baffles stack. This isn’t for the novice. While there are many theories Used for clipping baffles I am using the same method used by Q suppressors and SIG in their “Trash Panda”. I am currently building a jig to not only drill the cup but clip the end and drill 5 symmetrically placed ports close to the outer skirt using a small end mill (not a drill bit). All the cups, tube, end cap, adapter, and muzzle break and internal spacer are titanium.
Final note, it is cheaper to purchase a suppressor over building your own, I chose to build my own because the paperwork to build was faster and I wanted to prove to myself; and flex my skills I front of my girlfriend, that I’m an independent woman and I can do just fine on my own. To be honest I’ll probably by an OSS at a later date, probably after the wedding cause if I buy a can and not a matching pair of wedding dresses I’ll be sleeping alone on the back porch… if I’m lucky.
-Ammo:
-Federal American Eagle Subsonic 220
-Fiocchi FMJ 150
-Barnes VOR-TX 120 Grain Boat tailed ballistic tipped.
-Magazines: various mags from Magpul and some small 5 round mags for hunting.

So this about covers the build from top to bottom and it’s been why I’ve been so quiet for the past couple weeks, I’ve been hard at work completing the rifle that will be replacing my very tired Model 700 I’ve been hunting with for years.

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@ENTroPicGirl, Correct me if I am wrong but I thought vertical grips are not allowed on SBR only angle grip or some kind of hand stop. As your picture shows a vertical grip.

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@killingjoke

Correct me if I’m wrong but that is an arm brace on @ENTroPicGirl AR making it a pistol not an SBR and that forward grip looks to have a slight angle to it (although reversed) not making it a vertical grip but actually an angled grip?

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@dave67 Good eye Sir, My bad

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It’s angled have mine slanted forward slightly, I am currently awaiting a sanding disk to tailor it some to fit my hand better, to be honest it’s way bigger than I wanted it to be.
As far as the arm brace goes, technically yes it’s an arm brace but an arm brace can also be considered a stock depending on its use, the guy I spoke to had said pistol braces skirt the edges of the law while technically a brace they are still considered a stock if you are holding pocket it up to your shoulder like a proper rifle.
To be honest it’s all just so stupid, cause I have an aunt who hunts with a 30/30 Thompson Centre single shot pistol with a shoulder stock on it. No one has ever said anything one way or the other in 25 some odd years to the contrary.

Please correct me if I’m wrong though, the damn ATF guidelines are so vague on the stock thing. When is a pistol brace a brace, when is it a stock? Design or use or combination of both. Not reason I’m using this is because when I ordered the upper it came with it. Cause no one is marketing the upper as a SBR it’s sold as a pistol so it came with this brace or a blade. Now the blades now have an end cap that though make it look a lot like a stock but the strap technically keeps it in the murky area of being a brace.

Meanwhile you can hold your rifle, pistol, SBR, or potato gun against your forehead like a unicorn horn and shoot it and that’s not illegal in any state despite being incredibly unsafe to the user and anyone down range. You can suspend yourself upside down and shoot one handed and that too is perfectly legal. Hold your braces pistol to your crotch cover your self in peanut butter and your braced pistol in jelly and wave a lasso over your head while screaming the national anthem and firing off round after round and that’s legal. Just be sure not to touch it to your shoulder.

(Deep sigh) I paid 200 and change to touch it to my shoulder, did I make a mistake?

Side note Personally I don’t under understand what ATF considers this to be a “SBR” cause at just over 5’5” my SBR looks proportional in my hands. Sure give it to my older brother who’s over 6’ and it looks like a pistol but to me it looks and feels like a rifle brace or no brace.

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@ENTroPicGirl

I have always been told at my range as long as you have your pistol brace more towards your chest area than shoulder area than you are fine, every range I’ve been to doesn’t even monitor that. I have never seen anyone shooting an AR pistol and actually using the arm brace on their arm, always from the chest area.

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The ATF has issued several letters to attempt to clarify the use of a pistol brace.
Their stance now is that a brace may be shouldered “occasionally” without violating any laws. Not sure exactly how many times “occasionally” is but I digress.
Any rifle under 16” barrel length is an SBR requiring a Form 1.

Good information here:

If you’re new to the AR pistol game (or black rifles in general), it’s important to know a few laws and ATF regulations concerning how firearms are classified, lest you wind up in legal hot water:

  1. An AR-15 rifle must have an overall length of no less than 26".
  2. An AR-15 rifle must have a barrel that is no shorter than 16".
  3. An AR-15 pistol can have any barrel length, but no buttstock.
  4. An AR-15 with a barrel shorter than 16" and a buttstock is an SBR.
  5. An SBR (short-barreled rifle) is an NFA item and requires a tax stamp.

Can you shoulder an AR pistol stabilizing brace?

Yes. In 2014, the ATF argued this was illegal. But in 2017, they reversed their opinion and now state “sporadic, incidental, or situational” shouldering of a pistol brace is legal.

To answer that question, here’s a little background: In 2012, Sig Sauer unveiled their new SB15 Pistol Stabilizing Brace. This is the original brace that sparked the whole debate. It was intended to be strapped around the forearm, improving stability when firing. Some pistol owners saw an opportunity to instead use the pistol brace like a buttstock, pressing it up into the shoulder and using it as a cheek rest like you would with a rifle.

2014: ATF rules against shouldering braces

Angry politicians started crying foul over the Sig shoulder brace saga. So, the ATF released a statement that said shouldering a pistol brace would make your pistol an SBR, which is illegal:

"Consequently, the attachment of the SB-15 brace to an AR-type pistol alone; would not change the classification of the pistol to an SBR. However , if this device, un-modified or modified; is assembled to a pistol and used as a shoulder stock, thus designing or redesigning or making or remaking of a weapon design to be fired from the shoulder; this assembly would constitute the making of a ‘rifle’ as defined in 18 U.S.C. Section 921(a)(7).

“Further… in the designing or redesigning or making or remaking of a weapon designed to be fired from the shoulder, which incorporates a barrel length of less than 16 inches; this assembly would constitute the making of “a rifle having a barrel or barrels of less than 16 inches in length”; an NFA firearm as defined in 26 U.S.C., Section 5845(a)(3).”

Basically, the ATF said you can install a pistol brace, but you can’t shoulder it. If you do, you’ve redesigned your pistol into a rifle with a barrel less than 16", making it an SBR. This would make your pistol an illegal NFA item since you did not file the appropriate ATF paperwork nor obtain the $200 tax stamp required to own an NFA weapon.

2015: ATF defends stance on “illegal shouldering”

Naturally, a lot of gun owners took issue with the idea that simply shouldering a weapon meant you’ve somehow redesigned it. So, Max Kinger, Acting Chief of the ATF’s Firearms Technology Criminal Branch, issued another letter reiterating the agency’s position:

“The pistol stabilizing brace was neither “designed” nor approved to be used as a shoulder stock, and therefore use as a shoulder stock constitutes a “redesign” of the device because a possessor has changed the very function of the item. Any individual letters stating otherwise are contrary to the plain language of the NFA, misapply Federal law, and are hereby revoked. Any person who intends to use a [pistol] stabilizing brace as a shoulder stock on a pistol (having a rifled barrel under 16 inches in length or a smooth bore firearm with a barrel under 18 inches in length) must first file an ATF Form 1 and pay the applicable tax because the resulting firearm will be subject to all provisions of the NFA.”

2017: The ATF reverses, finalizes its opinion

Gun owners and manufacturers did not back off the pistol brace argument. The ATF began receiving letters from the industry challenging their opinion. The ATF probably realized it would be next to impossible to argue that simply holding something differently than intended would convince a judge or jury that it constitutes redesigning a product. SB Tactical, a pistol brace manufacturer, hired a lawyer who contacted the ATF.

When contacted by SB Tactical, ATF reversed its opinion and issued a final letter in March, 2017:

" With respect to stabilizing braces, ATF has concluded that attaching the brace to a [pistol] as a forearm brace does not make a short-barreled rifle because the configuration as submitted to and approved by the ATF is not intended to be comfortably fired from the shoulder. If, however, the shooter/possessor takes steps to configure the device for use as a shoulder stock – for example, permanently affixing it to the end of a buffer tube (thereby creating a length that has no other purpose than to facilitate its use as a stock), removing the arm-strap, or otherwise undermining its ability to be used as a brace – and then in fact shoots the firearm from the shoulder using the accessory as a shoulder stock, that person has objectively ‘redesigned’ the firearm for purposes of the NFA."

“To the extent the January 2015 letter implied or has been construed to hold that incidental, sporadic, or situational use of an arm brace (in its original approved configuration) from a firing position at or near the shoulder was sufficient to constitute ‘redesign’ , such interpretations are incorrect and not consistent with ATF’s interpretation of the statute or the manner in which it has historically been enforced.”

That’s a long-winded, wishy-washy answer. Here’s the simple summary:

  • In this letter, the ATF claimed they never said shouldering a pistol brace was illegal (which, in fact, they tried to).
  • The ATF clarified that modifying a brace in any way and then shouldering it constitutes making an NFA item.
  • The ATF said that occasional use of an unmodified brace does not constitute making an SBR or NFA item.
  • Sporadic means, "O ccurring at irregular intervals or only in a few places; scattered or isolated. "
  • Situational means, “Relating to or depending on a situation.”
  • Incidental means, " Unplanned."

Can I still shoulder a pistol brace?

Yes , as much as the ATF doesn’t want to admit with plain English. But there’s one big caveat: Don’t show it off.

Including the words “incidental”,“sporadic”, and “situational” when saying shouldering a brace is legal is the ATF’s way of backing off the issue without just saying “yes, it’s legal, go for it.” Using such language is the ATF’s way of trying to sway gun owners from doing this utterly harmless task consistently in order to satisfy the complaints from uninformed anti-gun politicians. So, you can do it. But in the strange, small chance you’re standing in front of a zealous ATF agent at your local gun range, we don’t recommend you do it consistently. Only occasionally .

Summary

  • In 2014, the ATF said that shouldering a pistol brace meant your pistol would be classified as an SBR.
  • In 2015, the ATF defended their opinion, claiming using a brace as a stock constitutes a weapon “redesign”.
  • In 2017, the ATF reversed their opinion, saying use of an unmodified arm brace as a buttstock isn’t illegal.
  • As of 2020, the ATF has not changed their last opinion. You can still shoulder a pistol brace.
  • We don’t recommend shouldering your brace all the time, according to the ATF’s vague language.
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Current ATF Interpretation allows brace to shoulder contact. And a pistol can be carried out of my state without permission.

IMO, it is all silliness rooted in some movie featuring a trench coat.

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@Dred
Exactly correct.
I have been putting together these pistols since the brace first appeared in 2012.
The ATF has a problem clarifying these things and for a long time it was down to the opinion of the letter writer.
At least now there is clarification on their use which is a step forward IMHO.
For me the advantage of these braces is as @Dred states. It is a pistol and therefore is treated as a pistol without the restrictions attached to Form 1 firearms.
Some builders will use a brace as a stop gap while they wait for the Form 1 to process with the intention of replacing the brace with a stock once the Form 1 is completed. I’ve done this myself.
So the question arises “Why bother with a Form 1 and $200 Tax Stamp?”
Good question, simple answer: because it gives the builder a much larger choice in stocks and if the ATF changes it’s opinion of use of pistol braces or possibly design of pistol braces, the SBR will not be affected.
I have had discussions with a couple of ATF agents regarding the use of pistol braces and interestingly their biggest concern was people adding a vertical grip to the hand guard. It’s a grey area I know but…you are dealing with the Government and they’re not known for their flexibility and understanding.
A good thing to remember with all Class 3 stuff is to always carry a copy of your paperwork wherever the gun or suppresser goes. You never know when an ATF agent may be lurking!:wink:

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(Deep sigh whilst unclentching fists)
So I could have saved 200 dollars, and really thats all it came down to. I already threw 200 at them for the suppressor and did the SBR at the same time.

IDK I’d like to be more upset about it but it’s what ever. To me money comes and goes, I’ve spent 500 dollars at Alta for makeup that I wipe off after a night of clubbing in Denver. What’s a few hundred to the ATF I make roughly 100 an hour turning out vintage motorcycles out of my garage, hell im about to go out to my garage today and clean and tune 4 carbs on a ‘77 Suzuki GS550X4, By sundown I’ll have made all the money I handed the ATF and then some. As as far as not being able to travel with it, I’ll take my upper and all my goodies throw them on a second lower pull the piston and turn off the gas throw in 5 round magazines and call it a straight pull bolt action pistol for when I travel back to PA/VT/MD where I go deer hunting with my family. The only reason I paid the ATF their due was so I could shoot at my local range and not have to deal with the ATF.

So anyone have an opinion on the “assault rifle bans”, as I see it it’s impossible since all AR and virtually all gas operated locking breach rifles can easily converted to a str8 pull manually operated action in under 30 minuets. Even my SBR status doesn’t denote semi or manual operated bolt. As far as I see it looks t would be a failure before it even started.

BTW great bit of research there. I copied all that and saved it to a file. If I ever have any issues with the ATF I’ll show them that and ask from them to just make up their mind. I went the safest way with this I could.

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No problem, happy to help.
Getting the ATF to make up their mind?! Don’t know about that :joy:

The Tax Stamp sucks and we have Al Capone and his buddies to thank for that but at least you’ll have the stamps and as you state you can always have a lower as a dedicated pistol you can add an upper to for travel etc.
I always carry a copy of the ATF definition when I visit a public range with one of my pistols.
Nice looking pistol/SBR by the way. :+1:t3:

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You hit the nail on the head there, this is all based around laws made back in the era where bad guys wore long trench coats sported Tommy guns and talked like Edward G. Robinson and Humphrey Bogart. “… you’ll can’t catch me cop’ah…” I’m amazed that we are still suffering from laws written as a knee jerk retort to the sensationalised fiction marketed as fact in William Randolph Hearst’s newspapers, they made it seem like every street level thug was carrying a Tommy gun and sawed off shotgun.

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Not much has changed over the years. :rofl:

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Realising I’m dealing with the lowest common denominator; police and ATF agents, I made laminated copies and digital copies the first day. My Trust was set up a couple years ago when I bought my Thompson Machine suppressor. I was surprised that my trust was approved, since it wasn’t names (last name) Trust, I chose to push the limits and be damned they let me do it. If I had known I would have called it “In Bob we trust” reference to church of the sub genius.

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Just a note:
That we all kvetch about the murkiness of the ATF’s wording and bemoan dropping the coin to pay for paperwork to own these firearms I’d like to point out to all that we live in a country that allows us to own these firearms and to kvetch openly without fear of being put up against a wall and shot for doing so. I giggle like a Japanese school girl every time I look over and see my SBR and realize I made that and I’m allowed to do so.

Well, I’m off to go make some money… an airbrush and Cerakot isn’t gonna buy itself.

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@ENTroPicGirl
Can’t argue with those statements, I’m thankful everyday for the freedoms of our country and those that defend and protect it.
Politicians?..Not so much.:us:

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I have to admit that I do the same. :rofl:

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So upon further checking I’m not going to risk it, for now I’ve cut an inch off of it making it definitely not a vertical grip and ordered something else. Oh dear lord help me, my GF is gonna flip when the UPS driver arrives with yet another package.

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@ENTroPicGirl

I guess better to be safe than sorry.

You sound like you work hard for your money, spoil yourself.

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IMO, it is still a vertical foregrip. I swear I read that you SBR’d this shooter. If you did, you’re good with vertical, angled, twisted or catiwhompus - there are no restrictions on a legal rifle.

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