Prestigegunleather, since you aren't my client and I don't know all of the facts, I cannot speak to your situation. I would advise my own clients not to rely on ATF legal opinions unless they are in writing and directed to them personally regarding their specific question.
However, like the others, I would certainly appreciate you posting that letter when you receive it. From a legal standpoint, that would be quite a switch in ATF policy.
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(Meaning that it will now become an SBR coverted from a rifle???) All this according to BATF regs? Or am I getting really confused?
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You are confused. See Revenue Ruling 61-203 for the explanation on carbine kits for pistols.