A new type of firearm
An interesting debate over at CleanUpATF.org. It's complicated, but I believe concerns what do you have when you have a shotgun with length below the NFA limits, but originally made with a pistol grip instead of a shoulder stock? Is it an ordinary handgun, since it is not designed to be fired from the shoulder? Is it an NFA arm, more regulated, since it is a shotgun with short barrel? Or is it a destructive device, most regulated of all, since it is over .50 caliber and not within any exemption?
Add to that ATF's ability to change its rulings at any time... is the current ruling, that it is an ordinary handgun, an attempt to sucker in the proposed manufacturer (against whom ATF has a serious grudge match) and then, after he has invested in making the firearms, reconsider, seize and forfeit the firearms, and put his production line out of business?