ATF takes the position that this includes any combination of parts from which a short barreled rifle can be assembled. And they said this included a set of parts with dual uses. In the Supreme court case of Thompson/ Center Arms v. US, – U.S. – (1994) ATF said it was a set consisting of a receiver, a 16″+ barrel, a pistol grip stock, a shoulder stock, and a barrel less than 16 inches long. The idea of the kit was that you needed only one receiver, and you could have both a rifle and pistol in one gun. While making a pistol out of a rifle is making a short rifle, ATF has long approved of converting a pistol into a rifle, and then converting it back into a pistol, that was not an issue. T/C made one set on a Form 1, then sued for a tax refund, claiming the set was not a SBR, unless it actually was assembled with the shoulder stock, and short barrel, something they instructed the purchaser of the set not to do. The Supreme court disagreed with ATF, and agreed with Thompson/Center.
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