Pistol from a rifle kit?

I just got a Bulgy 74u demilled kit. I want to assemble this as a pistol. Is this possible? Do I just just buy the Nodak NDS-2SF premium, "round tab" reciever and not install the folding stock? Will i need to buy a different rear trunion? I have other folders and want a pistol, that would be able to use all the parts esp the flash suppressor and not have to be "compliant". Anything else I would have to do?

You absolutely can't install the trunion that came with the kit. If you did, you would have an SBR. You'll need to install a pistol trunion. You can use an NDS-2 receiver.
http://www.nodakspud.com/images/NDS2c-web.jpg

On the other hand, if you live in a place where you can get approved for an SBR, then I think you should definitely make an SBR. The process is really not difficult and it will only cost you about additional $200 to build it the right way. And... it doesn't have to be "compliant".

if you layed out the big money for a 74U parts kit, make it a SBR.....unless you live in a state that doesn't allow SBR.

pistols look cool, but they suck shooting them.

You absolutely can't install the trunion that came with the kit. If you did, you would have an SBR. You'll need to install a pistol trunion.

Are you 100% sure this is correct?

To my understanding, it's all about "constructive intent". In other words, using the side folding rear trunion, and just having the mating stock in your posession fulfills the "ability" to build an NFA element, which automatically creates the "intent" element. Therefore, NFA violation.

However, having the pistol be SBR-ready, but not having a mating stock in your posession should not create "constructive intent", as you have no "ability" or "means" to make an NFA weapon.

For example, I know that merely having an AR-15 upper less than 16" in your posession without a registered lower "is" a violation via "constructive intent".

Another supporting reason I have for "thinking" that use of the rear side-folding trunion (without posession of a stock) is fine, is that I purchased a Vector V-53 (.223) pistol late last year, and they come with a back plate that takes 10 seconds to remove. But the frame of the weapon is grooved on both sides just like the original HK-53's. All I had to do was get a tax stamp, then slap on a collapsable stock. In other words, just having the pistol be SBR-ready was not an NFA violation since I did not buy a stock until "after" getting my tax stamp, so as to avoid the "constructive intent" element.

Ultimately, I don't expect you to take my advice on it being OK, as I'm not an attorney or NFA brach rep. But you can always call NFA branch to confirm for yourself.

However, having the pistol be SBR-ready, but not having a mating stock in your posession should not create "constructive intent", as you have no "ability" or "means" to make an NFA weapon.
From what I have read, you are exactly correct. I just assumed that he would have the stock from the kit in his posession.

Yeah, if he has the stock, he should just leave it with a non-Krink owning friend until he gets his tax stamp.

I'm just gonna go for the stamp and build it the way it was intended, thanks for the input guys!

I'm just gonna go for the stamp and build it the way it was intended, thanks for the input guys!
Good move!

there is a reason the atf wont allow a front handguard on a pistol(the pistol grip fronts). Because it would be great to have for handling recoil for a quick follow up shot. They know just how to dampen a good thing to make it less enjoyable all around. I have one and i love it, but to shoot, I would get one more that has a grip.

You talking about a hand grip or a vertical grip? I didnt plan on changing th egrip on my Bulgy Krink kit.

This is the first time I've read that you need a pistol trunion when builing a pistol from a modified rifle kit. I've not built the pistol yet, but I don't want to inadvertantly build a SBR.
If this is accurate, can someone point me to the regs that state you need a pistol trunion when you have a pistol receiver?
Thanks.


You absolutely can't install the trunion that came with the kit. If you did, you would have an SBR. You'll need to install a pistol trunion. You can use an NDS-2 receiver.
http://www.nodakspud.com/images/NDS2c-web.jpg

On the other hand, if you live in a place where you can get approved for an SBR, then I think you should definitely make an SBR. The process is really not difficult and it will only cost you about additional $200 to build it the right way. And... it doesn't have to be "compliant".

Read Tactical_T's response. The regs don't say that you have to use a pistol trunion. However, if you install the trunion that came with the kit and also have access to the folding stock, then they can bust you for "constructive intent". The reason I say that you should use a pistol trunion is twofold. First, it makes it so there is no way that they can claim you have access to a stock to install on the pistol. Second, it looks better because it doesn't look like the buttstock is missing. You should be able to easily trade the rear trunion and associated hardware that came with your kit for a pistol trunion.
As far as where the regs are, I'd like to know also. Perhaps someone can point us in the right direction.

Unfortunately there are no actual "regs" regarding this. The problem was ATF used to say having the a short bbl firearm and a stock to fit it automatically equaled an SBR even though it may have never been assembled that way. Thompson Center wanted to market a pistol/carbine kit version of their Contender handgun, essentially a case containing a Contender frame, a short pistol length bbl, a long rifle length bbl, and a pistol grip and interchangeable buttstock. ATF sez you got an SBR there, even though the stock and instructions are plainly marked to only be installed in conjunction with the rifle bbl and it had never been assembled in an SBR config.

TC paid the $200 makeing tax and got one kit registered as an SBR. They then sued ATF for a tax refund, arguing the kit had several possible ways to assemble a firearm, only one of which was an SBR and it had in fact never been assembled that way. Went all the way to the Supreme Court and they ruled in TCs favor.

The result is SCOTUS essentially made up a legal test. If a "group of parts" COULD be assembled in a legal manner, it was to be assumed the owner only intended to assemble them in a legal manner. Unless, of course, they had hard evidence that it was in fact assembled in an illegal configuration, or intended to be. IIRC, the example they used was that under ATF's line of reasoning everybody who owned a shotgun and had a hacksaw in the garage was guilty of owning a sawed off shotgun, even if the bbl was currently of legal length. Under the new test you actually had to saw off the bbl or at least show your intent to do so. (Saw and shotgun on bench, tape wrapped around it marked "cut here" perhaps?)

So, if one has a handgun capable of accepting a buttstock, one either has to have a longer bbl to install when it is installed (easy with a Contender or say a spare upper for an AR15, more difficult with an AK) or have no stock capable of fitting it in your possession.

Many legal handguns have had shoulder stock attachment points, the Luger, Mauser C96, even a lot of Browning Hi Powers have all come factory equipped with shoulder stock lugs. Just don't buy a replica stock and you're legal.

Here's the link to the SCOTUS opinion:

http://www.cs.cmu.edu/afs/cs.cmu.edu/user/wbardwel/public/nfalist/thompson.txt

And Bardwell's summary of it can be found here:

http://www.cs.cmu.edu/afs/cs.cmu.edu/user/wbardwel/public/nfalist/nfa_faq.txt


"ATF takes the position that this definition 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 U.S. v. Thompson/Center Arms
Co., 504 U.S. 505 (1992) ATF said a set consisting of a receiver,
a 16"+ barrel, a pistol grip stock, a shoulder stock, and a barrel
less than 16 inches long was a short barreled rifle. 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 approved of converting a
pistol into a rifle, and then converting it back into a pistol,
without "making" a short barreled rifle when it is converted back
into a pistol; that was not an issue. See, for example Revenue
Rulings 59-340, 59-341 and 61-203. 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.

The Court said that a set of parts was not a short barreled
rifle, unless the only way to assemble the parts was into a short
barreled rifle. As this set had a legitimate, legal, use for all
the parts it was OK. However they also approved of lower court
cases holding that the sale by one person, at the same place, of
all the parts to assemble an AR-15, with a short barrel, was sale
of a SBR, even if they weren't assembled together at the moment of
the bust, and had in fact never been assembled. See U.S. v.
Drasen, 845 F.2d 731 (7th Cir. 1988). This was because the only
use for the parts in that case was a SBR. If the person in that
case also had a registered M-16, then there would be a legitimate
use for the SMG barrel, and there shouldn't be a problem. And the
Court agreed, of course, that a fully assembled rifle with a barrel
less than 16", or an overall length of less than 26" was also
subject to registration. Although it was not addressed in the
case, the rule is that an otherwise short barreled rifle that is
very easily restored to firing condition (readily restorable);
e.g., one missing a firing pin, but for that pin one may substitute
a nail or other common object, is also subject to the law.