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There is no set length of time you must hold on to a firearm before selling it. However the length of time you own it before selling it would certainly be used as evidence of your intent when you purchased the firearm.
If you own a gun for a year before selling it that length of time would tend to show you intended to purchase it for yourself.
If however you purchased a gun and then sold it 24 hours later that would tend to show you did not intend to purchase it for yourself.
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