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HKFan9 I thought that the ATF updated the ruling on this stating for AR's and pistols with Mech-Tech uppers, you can switch back and forth between the two, so as long as you followed NFA guid lines... for example, you can't stick a 10'' upper on a lower that has a buffer tube and stock attached, but you can put a 10'' upper on a lower assembled with a smooth pistol buffer tube.
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That ATF determination has nothing to do with the OP's question.......because the OP's firearm is not yet a pistol or rifle.
If the OP builds the firearm as a pistol first, he can subsequently build it into a rifle and later back to a pistol.
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