[gyvel]

In almost every call I've made to ATF they don't give advice or an interpretation- they quote ATF regulations word for word.

NEVER. NEVER. NEVER, rely on verbal answers from ATF (or for that matter IRS, USPS or any .gov agency).

Time and time again, they are proven wrong. ATF is notorious for issuing conflicting opinions in WRITTEN format. An example of note is the legality of attaching a wooden stock/holster to certain Mauser, Luger & Browning/Inglis Hi Power pistols. In 1981 ATF's Technical Branch issued a ruling that reproduction stock/holsters were okay, several years later they issued another ruling that only original stock/holsters were okay to attach without violating the NFA.

You know it. And that is why I am going to submit this to Martinsburg this coming week and get an answer IN WRITING.