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If it's produced only as a rifle, it doesn't matter if that particular receiver ever got a barrel or not, it is legally a rifle.
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"from a weapon originally assembled or produced only as a rifle".
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And I have to disagree here. I had this same conversation earlier this afternoon in the LGS, and was shown some pistols made up on Remington receivers by MacMillan that were not "assembled" (the key word here) as rifles. Also, the reg says "produced" as in a receiver that has already been barreled and assembled, not "will possibly be."
It's pretty clear that a new, virgin unbarreled and never has been barreled receiver is not a weapon. Making a pistol, as I stated earlier from an assembled "weapon," i.e. a completed item that was produced and meant to be sold as a completed rifle, is making an illegal SBR. It's not the same if the receiver has never been made into a rifle.
If what you say is true then there can't be AR15 pistols since the AR 15 "is produced as a rifle." The Ruger Challenger can't be made as a pistol either since 10/22s are "produced as a rifle." Same deal for the Chiappa Mare's Legs, since the Winchester copy receivers are "produced as a rifle."
And since Ruger has seen fit to make a 10/22 pistol, I don't see why they can't use their 77 actions to make a bolt action pistol. Agreed?
I'm guessing that they are not rifles as far as BATF is concerned until they are barreled as such.