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No way in hell I would sell 12 rifles from a C&R collection in a year, or 5 years for that matter. In fact, I choose to avoid it altogether. If I imagine myself in an agent's shoes, I would find 12 sales per year highly suspicious, and I'm far from uptight.
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Oh would you? What if the C&R holder purchased 60 and sold 12? There is no "set number" for any of this.
This topic is far from cut and dry. There are too many variables here to deal with absolutes. The only thing that is for sure is that the ATF will do what they want regarding this stuff. Beyond our own interpetation of the rules / laws, it is theirs that is most important.