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The ruling doesn't address an importer/manufacturer contracting work to a non-licensed company or individual. It specifically addresses "any person licensed as a dealer-gunsmith performing certain processing or finishing on firearms owned and marked by a federally licensed firearms manufacturer."
The intent is not to determine whether a person doing contract gun work needs to be licensed; that is another issue. Also, whether a licensed dealer-gunsmith also does non-firearms work is irrelevant and outside the scope of BATFE interest or control.
What is addressed here is whether a licensed dealer-gunsmith can perform such contract work for an importer/manufacturer without himself being licensed as a manufacturer; the ruling is that he may do so, essentially the same way he can perform the same services for any individual.
Jim
Last edited by James K; January 1, 2011 at 12:10 AM.
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