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  1. I don't believe that is quite the circumstance....

    I don't believe that is quite the circumstance. Rather, as I understand it:

    i. The ATF is creating a presumption, unsupported by the statute, that will result in some persons who are not currently...
  2. I would like to thank those who participated...

    I would like to thank those who participated constructively, volunteering their observations in a way that improved what I was able to file. I regret to note that my teaching obligations have left me...
  3. I had neglected to mention in my draft the zoning...

    I had neglected to mention in my draft the zoning issue. Thanks for reminding me! This post is quite helpful.
  4. DMF13 You've identified the premise of your...

    DMF13

    You've identified the premise of your observations as concerning
    , which you reference as your I gather it is now clear that this premise is not accurate (influencing the language of the...
  5. I thank you. I tried searching for duplicate and,...

    I thank you. I tried searching for duplicate and, I believe, sacrificial, without success at least as to the basic scope of the main post.
  6. Indeed I did.

    Indeed I did.
  7. Ahhh. I was hoping you would see the thread....

    Ahhh. I was hoping you would see the thread. We've briefly met once, at a convention.

    I concur, of course (though I did not know about the comment).

    [Edit to remove items perhaps better not...
  8. I very much thank you for taking the time to...

    I very much thank you for taking the time to respond.

    One of your former students
  9. John-- Please allow me to express my sincere...

    John--

    Please allow me to express my sincere thanks for your efforts on this. I was sure that someone on this forum would have contacts with people who have the widest access to info, if anyone...
  10. I thank you for your observations. The current...

    I thank you for your observations.

    The current stage of the proceedings involves assuring that the agency record contains citations to relevant information that illuminates the impact the proposed...
  11. All words are “made-up.” Words are not delivered...

    All words are “made-up.” Words are not delivered by a divine authority. Google informs me Merriam Webster added 690 words in September 2023.

    But significantly, it would appear that there is a bias...
  12. I thank you for taking the time to forward your...

    I thank you for taking the time to forward your thoughts. I agree the proposed rule is unclear.
  13. Although my views on legal realism are not likely...

    Although my views on legal realism are not likely to be relevant to what I write, I note, Judge James C. Ho, a Federal appellate judge, wrote in a judicial opinion, "Constitutional rights must not...
  14. The proposed regulation says "new or like new."...

    The proposed regulation says "new or like new." The term is not defined.

    A side note: If a regulator wishes to suppress some activity, one way to do that is to issue a rule that is vague.
  15. Thanks for the comment, Hambo. I did not...

    Thanks for the comment, Hambo.

    I did not amplify on the precise context. The ATF has proposed this rule. They have asked for comments.

    One of the things people do in comments is point out to...
  16. Hambo-- Thanks for your comment. That is...

    Hambo--

    Thanks for your comment.

    That is the relevant section. Let me delete the irrelevant material from the proposed language, so that it reads.

    "A person shall be presumed to be engaged...
  17. HCM: Thanks for your thoughts. It seems to...

    HCM: Thanks for your thoughts.



    It seems to me at least possible that some of these materials include a brief excerpt that is designed to reinforce the notion that one should train. In the...
  18. To amplify, if I may, Okie John wrote: ...

    To amplify, if I may, Okie John wrote:



    Having any source I could cite for that would be quite helpful (if one does not want a registry). Lots of trainers hand-out pamphlets that have...
  19. Thanks for your thoughts, okie john! The...

    Thanks for your thoughts, okie john!

    The current administration has and is taking a number of steps to something that is as much like a registry of firearms as they can without violating Federal...
  20. Thanks for the observation. That had been my...

    Thanks for the observation. That had been my casual observation as well.

    To put this in context: Federal law currently does not allow the Federal gvt. to create a registry of ordinary firearms....
  21. DamonL-- Thanks for the thought. It's actually...

    DamonL--
    Thanks for the thought. It's actually worse than that. If one is a licensed dealer, one's premises are subject to warrantless inspection by the government. And if the stuff is in one's...
  22. I agree it's unlikely, but one never knows. There...

    I agree it's unlikely, but one never knows. There are lots of academics that get paid to do research, and they often can address whatever they want, and opt to do something not apparently useful. I...
  23. There is a definition in the statute. It is this:...

    There is a definition in the statute. It is this: "(11) The term "dealer" means (A) any person engaged in the business of selling firearms at wholesale or retail, (B) any person engaged in the...
  24. RFI to Reply to ATF Rule Proposal Expanding "Dealer" Def'n--Guns Bought But Not Fired

    I was hoping someone might know of survey info. re the frequency with which new guns are bought but fired little.

    I'm a retired law prof who taught firearms law. I'm in the process of replying to...
  25. Replies
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    Hello: You have, in the above post, quoted TGS...

    Hello:

    You have, in the above post, quoted TGS to the following effect, "IMO, we don't need to be encouraging executive regulatory agencies to ordain us with more interpretations of laws....."
    ...
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