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Bolt Action Pistol Build

I think this is the key to your question! Please note, any person engaged in the business of manufacturing firearms (including assembly) is a firearms manufacturer. The term includes any person who engages in such business on a part-time basis. A manufacturer must obtain a Federal firearms license prior to engaging in the manufacture of firearms. You are encouraged to contact your local ATF office regarding these issues.

If you have a manufacturing license, build it from an Brand New Action only, & meet all other specs. And sell it as a pistol it is a legal Pistol!
 

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