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You could have 1 SBR lower, 5 short uppers, a rifle lower with no uppers in the house and be legal.
You have proof of no "intent" since you have a legal use for each of the short upper.......
Lower must be engraved with the manufacturers info, on a form 1 that's you
... You can keep being told this but until you get it it's pointless...
NWcid- what say you on my take on it? It looks confusing as hell, but most things are in ATF land. part of this also has to do with ATF letters both to people and to FFL's on the issue.