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What is an AR-15 receiver?
Some interesting thoughts on an emerging legal problem. Bottom line: the upper does a better job of meeting the regulations' very general definition, and there is no specific regulation that says the lower is the receiver.
The obvious solution is a regulation that says the lower is the receiver, but I suspect the agency will be worrying about opening a can of worms, and so won't promulgate such a reg unless forced by circumstances to do so.
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"Be thankful we're not getting all the government we're paying for."
Will Rogers
The vast majority of the anti 2A crazies don't know an upper from a lower, or a receiver from a pistol frame. They would be happy to have every part, accessory, and magazine, serialized and NICS checked, with a 100% "sin tax" attached in addition to the regular fee.
The lower makes sense for an AR, for other types of weapons with a split receiver, the upper makes more sense. Not that it has to make sense: On an M2 the right side plate is the magic piece.
I would not trust the government to make the decisions though: They could simply NOT decide...and dry up the supply