Category Archives: Firearms Law

US Supreme Court Decision Affects Firearms Rights – Ability to Obtain Relief from Certain DUIs!

On June 23, 2016, the U.S. Supreme Court decided that case of Birchfield v. North Dakota, 14-1468, in which the Court held that while implied consent laws relative to driving under the influence (DUI) may impose civil penalties, it is unconstitutional for them to impose criminal penalties for refusing to consent.

Specifically, as the Syllabus to the decision declares:

Motorists may not be criminally punished for refusing to submit to a blood test based on legally implied consent to submit to them. It is one thing to approve implied-consent laws that impose civil penalties and evidentiary consequences on motorists who refuse to comply, but quite another for a State to insist upon an intrusive blood test and then to impose criminal penalties on refusal to submit. There must be a limit to the consequences to which motorists may be deemed to have consented by virtue of a decision to drive on public roads. Pg 36-37

So how does this affect your firearm rights?

Under Pennsylvania law, if an individual refuses his/her consent relative to a second (or third) DUI, the criminal grading becomes a misdemeanor of the 1st degree, which is federally prohibiting for purposes of purchasing and possessing firearms and ammunition. I previously blogged about a similar situation in Pennsylvania, when the Pennsylvania Superior Court decided Musau. Unfortunately, as a result of the Superior Court’s decision, the General Assembly amended the statute, so that anyone who refused consent on a second (or third) DUI would be penalized by a misdemeanor of the first degree, instead of an ungraded misdemeanor (which would not be prohibiting under state or federal law).

As a result of the U.S. Supreme Court’s decision in Birchfield, those individuals in Pennsylvania who have been convicted or pled guilty to a misdemeanor of the first degree as a result of a second (or third) DUI, due to their refusal to consent, have been subjected to an unlawful sentence and have a limited opportunity to file for relief under Pennsylvania’s Post-Conviction Relief Act (PCRA).

Therefore, if you or a family member were convicted of a second or third DUI, where you refused to submit to chemical testing, contact us immediately, as you have the ability to petition the court to have your conviction properly reflect the grading as an ungraded misdemeanor, which would not trigger a state or federal firearms disability.

As Federal Firearms Relief is not currently available and the Pennsylvania Board of Pardons does not with any frequency grant pardons to those who have been convicted of repeat offenses, this may be your ONLY extremely limited opportunity to obtain relief!

Contact Us Today to Discuss YOUR Rights and How We Can Restore Your Right to Keep and Bear Arms – info@princelaw.com or 888-313-0416

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Filed under Constitutional Law, Firearms Law, Pennsylvania Firearms Law

ATF’s Shocking Position on “Makers” of Silencers/Suppressors, Especially in Relation to Solvent Traps

As many of our readers are aware, Attorney Adam Kraut and I attended the NSSF’s Import/Export Conference on August 2-3, 2016, for which we blogged about many of the statements made by ATF (and other federal agencies) in our blog – News from the Round Table Discussions at the NSSF Import/Export Conference. One issue that we did not discuss is ATF’s statements during the Round Table Discussions relating to ATF’s position on “makers” of silencers/suppressors, especially relative to what been called “solvent traps.”

For those who are unaware, there are a number of business offering “solvent traps,” which are designed to thread on the end of one’s barrel to capture the solvent, typically in an oil or fuel filter threaded on the end.

Oil Filter Suppressor 1Oil Filter Suppressor 2.jpg

While the use of these devices for purposes of collecting solvent is questionable, many of these companies advise their customers that if they want to be able to use the solvent trap as a silencer/suppressor, the customer must first file a Form 1 with ATF to make a silencer and receive approval, before utilizing the solvent trap for purposes of being a silencer. (While we would advise our clients to file a Form 1 and obtain approval of ATF prior to even purchasing a solvent trap or similar device, so to prevent against constructive possession charges, such is beyond the scope of this article).

Under the National Firearms Act (“NFA”), 26 U.S.C. 5801, et seq, one who wishes to “make” an NFA firearm must file an application with the Attorney General, pursuant to 26 U.S.C. 5822. (Although the statute still references the Secretary (of the Treasury), when ATF was moved under DOJ in 2003, it changed to the Attorney General). Under the NFA, pursuant to 26 U.S.C. 5845, “make” is defined as to “include manufacturing (other than by one qualified to engage in such business under this chapter [26 USCS §§ 5801 et seq.]), putting together, altering, any combination of these, or otherwise producing a firearm.”  While the NFA, pursuant to 26 U.S.C. 5841, does differentiate between a “maker” and a “manufacturer” in relation to how one is to initially register an NFA firearm  and does define “make” as mentioned previously, nothing in the NFA differentiates between the rights of a “maker” and those of a “manufacturer.”

Nevertheless, during a discussion on ATF-29p (ATF’s Advanced Notice of Proposed Rulemaking relating to Silencer/Suppressor engravings), ATF’s Mike Curtis and Earl Griffith with the Firearms and Ammunition Technology Division (“FATD”) stated that ATF views “makers” of silencers/suppressors differently than “manufacturers.” Specifically, the example of solvent traps was brought up, where they stated that ATF’s position is that a “maker” of a silencer cannot replace a silencer part without filing a new Form 1, paying another $200.00 and obtaining approval from ATF; whereas, a manufacturer, may lawfully replace a silencer part in a silencer it manufactured, provided that the part that is being replaced is destroyed. While there does not exist any specific statutory provision to support this contention, Mr. Curtis went on to explain that an individual who files a Form 1 to make a “solvent trap silencer” can only use the original oil/fuel filter that is installed and is barred from replacing a previously utilized oil/fuel filter with a new filter, absent a newly approved Form 1.

While Mr. Curtis did admit that to his knowledge ATF has not been asked to make a determination on a solvent trap silencer, he was explicitly clear that if a determination request was filed (or criminal charges brought against someone in such a situation), ATF would specifically find and contend that a “maker” of a silencer/suppressor may not repair/replace any part of the silencer/suppressor without first obtaining another approved Form 1.

Obviously, ATF’s position has a great impact on the Firearms Industry, as many individuals have made their own silencers/suppressors, long before the solvent trap silencers, and have been under the impression that like a manufacturer of a silencer/suppressor, they may lawfully replace a part in that silencer, provided that they destroy the part being replaced.

While Firearms Industry Consulting Group (FICG), a division of Prince Law Offices, P.C., does not agree with ATF’s position, we believe it is extremely important to advise those who have Form 1’ed their own silencer/suppressor of ATF’s position, since non-compliance could result in federal charging.

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ATF Responds to 4473 Comments and Apparently Does Not Care that It Violates Its Own Regulations

atf logo

Earlier today I received an email response from ATF in relation to FICG’s Comment in Opposition to ATF’s Proposed Changes to the 4473 Form which I drafted. You can find a copy of their response here.

In the comment I raised a number of issues including that ATF is the incorrect federal administrative agency for determinations of prohibition under 18 U.S.C. 922(g), that ATF cannot redefine a “fugitive from justice” in these proceedings, and issues relating to the certification statement. It was also requested that ATF revise the 4473 Form, consistent with the ATF Form 1 and Form 4, whereby it would include fields for fictitious entities, instead of requiring FFLs to draft and attach a fictitious entity form as required by 27 C.F.R. 478.124(g), for which, ATF provides no sample form. Most noteworthy, I challenged the language that ATF required individuals certifying information on the form to attest to.

Specifically, the individual is certifying that based on the

“…information in the current ATF Publication ‘State Laws and Published Ordinances’ – it is my belief that it is not unlawful for me to sell, deliver, transport, or otherwise disposes of the firearm(s) listed on this form to the person identified in Section A.”

The problem with that language is the the current publication of State Laws and Published Ordinances is the 31st version which dates from 2011. This means there is at least a 5 year lapse of information in the current guide.

atf

The important part is that ATF’s own regulations require that “[t]he Director shall annually revise and furnish Federal firearms licensees with a compilation of State laws and published ordinances which are relevant to the enforcement of this part.” See27 C.F.R. § 478.24.

ATF’s response was rather comical.

Screen Shot 2016-08-09 at 2.43.00 PM

Essentially, ATF said that they don’t care the regulations, which they drafted, require that book be updated but rather they would change the language so the individual signing the form would not need to certify they relied on that book for information.

As ATF has a long history of abusing its authority one cannot help but roll their eyes at the nonsense and lack of accountability the agency has. Perhaps some calls from concerned citizens to congressional leaders will help get ATF back on track.

 

Who is my Representative?

Who is my Senator?

 

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Extremely Interesting Developments Relating to ATF’s Re-Opening of the Comment Period for the ATF 4473

As our readers are likely aware, I previously blogged that ATF had re-opened the comment period for the ATF 4473 form. After digging a little deeper, I determined that OMB issued a PRA Primer Memo of April 7, 2010 directing that an agency, after providing the initial 60 day notice period required by 44 U.S.C. 3506(c)(2)(A), summarize the public comments received and any response by the agency, then submit that information to OIRA and thereafter provide an additional 30 day comment period so the public has an opportunity to respond to comments submitted.

Accordingly, on August 5, 2016, I submitted a correspondence to OIRA and ATF citing to the PRA Primer Memo and explaining that in relation OMB Number 1140-0020 “ATF has failed to provide either (1) the actual comments submitted or (2) any summary of the public comments received (as well as any response by the agency); therefore, depriving the public of any opportunity to know what comments were submitted and depriving the public of an opportunity to respond to those comments and thereby eviscerating the purpose of the 30 day comment period.”

Although I received no response from OIRA or ATF, today, Attorney Adam Kraut, who drafted our Comment in Opposition, initially received an email from the ATF Firearms Industry Program Branch (FIPB) in relation to his June 1, 2016 email inquiring as to why ATF was not posting or providing access to the comments submitted regarding the proposed changes to the ATF 4473. FIPB stated that “Comments received from this information collection will soon be available on the www.reginfo.gov website.”

Shortly thereafter, Attorney Kraut received a second email from FIPB with a response to Firearms Industry Consulting Group‘s Comment in Opposition. You can download a copy of ATF’s response to our Comment here. Additionally, I recently learned that ATF also emailed a response to our friends at Cannabis Industry Law Group in relation to their Comment in Opposition to the ATF 4473 and ATF provided this response.

It appears that OIRA was not exactly happy with ATF’s failure to comply with OMB’s requirements and directed ATF to correct its errors. It will be interesting to see if the 30 day comment period is extended to provide all interested parties with the requisite 30 days to respond, after ATF provides access to all comments received and its responses thereto.

If you are in the Firearms Industry and desire to file comments in relation to ATF, DDTC or any other federal agency’s rulemaking, contact us today to discuss how we can assist.

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News from the Round Table Discussions at the NSSF Import/Export Conference

It’s that time of year again, the NSSF Import/Export Conference which is held in Washington, D.C. While the conference is designed to help educate companies about the import/export regulations and laws they might encounter while in the business, the conference does provide for round table discussions with ATF, DDTC and other Firearm Industry officials. Some of the officials from ATF that I had the opportunity to sit around the table with were Ted Clutter (Section Chief of the NFA Branch), Earl Griffith (Head of the Firearms and Ammunition Technology Division [FATD]), Max Kingery (Second in Command at FATD) and Edward Courtney (Head of the Firearms Industry Programs Branch).

ATF

General ATF

Marvin Richardson, the Deputy Assistant Director of Enforcement Programs and Services, announced during the ATF Panel Discussion that there would be a new NFA Division (discussed further below).

Andy Graham Deputy Assist Director for Industry Operations reviewed some statistics from this past year.

Inspection statistics:

177 new importer applications

493 inspections occurred, 177 were related to importer applications, the rest were compliance inspections.

There was 1 application denial, 103 applications which were withdrawn for various reasons, 110 compliance inspections resulted in no further action, 36 compliance inspections that resulted in license surrenders,  and 15 special requests for inspections from licensing center.

There were 3 inspections that resulted in warning conferences and 14 inspections that resulted in a warning letter with a recall. There were also 8 inspections that resulted in a warning letter without a recall.

Last fiscal year, base of licensees dropped from ~141,000 to ~139,000.

Alphonso Hughes chief of the Firearms & Explosives Services Division reviewed changes to the structure of different divisions of ATF.

FFL Licensing Center has 20 examiners processing applications. FEL Licensing Center has 10 examiners working for it.

NFA Branch has 24 examiners staffing it. It’s down from 26. There are now 4 sections within the NFA Branch. That’s up from the previous 2. There are 7 vacant examiner positions that they are in the process of filling. Projections into 2017 for additional staff to help the NFA Branch.

Krissy Carlson, the chief of the Firearms and Explosives Industry Division, reviewed the new 4473 that is up for comment (again) on the Federal Register. For more on that see Chief Counsel Joshua Prince’s blog article. They are also introducing a newsletter that they’ve been working on since November! Krissy also mentioned new rulings based on petitions submitted to them.

Andrew Lange the Division Chief of the Officer of Regulatory Affairs spoke about the difference between regulations and rulings. There are a couple of rulemaking proceedings that are in the notice and comment phase. He specifically mentioned the ATF 29P notice and comment period closing today which I filed a comment in Opposition of the Advanced Notice of Proposed Rulemaking on behalf of Dead Air Silencers. You can find that comment here.

Lastly, Earl Griffith, the Chief of the Firearms and Ammunition Technology Division, spoke. There are some promotions within the division. They are on track to do over 1,000 marking variances this year. They are taking about 2-3 weeks to process.

 

nfa branch

NFA Branch

NFA Stats:

307,000 NFA Applications were processed. Last year there were 221,000. On track to receive about 400,000 forms for this year based on last years numbers. They are predicting 469,000 for this year because of ATF 41F (shout out to NFATCA).

Processing time is advertised as 6 months. In the last 5 weeks, they received 126,000 forms on top of the 90,000 they already have. 6 months now may be 8 or 9 months. Sorry guys. Just forget you ever submitted anything.

7,500 applications a week were received before 41F was announced. It doubled after the announcement of ATF 41F. It approached 35,000 in a single week closer to ATF 41F being implemented.

Alphonso said that the non-tax paid forms should be close to a 30 day processing time. He told his examiners to make that a priority.

They received several million dollar days in tax paid forms for the month of July. They cleared 11 million dollars in tax paid applications for the month of July.

They are looking to implement an electronic method for the submission of tax paid forms post 41F. Alphonso mentioned the possibility of electronic submission of the application and RP questionnaires with a matching barcode sheet to mail in the fingerprints.

NFA Branch is going to become a division with several branches within it to modernize the workflow. This is due to congressional oversight inquiries. They are looking for approval on paper in the first quarter of fiscal year 2017. Actual implementation in the 2nd or 3rd quarter. Alphonso will be the Chief of the NFA Division.

I also asked the NFA Branch a number of questions during the round table discussion. Before attending the conference I asked members of AR15.com, other industry related forums, and on Facebook questions they had that they wanted answered. I received a number of good questions which I decided I would ask.

Does ATF intend to bring back eForms for Form 1 and Form 4s?

Sounds like due to funding the eForms system will just be maintained where it is, until there is funding to replace it. In other words…

burea

Is the NFA Branch still accepting corrections to forms submitted that had “non fatal” errors?

Yes. They are.

Does the NFA Branch have any procedures in place for forms which were submitted with credit card information that was rejected for wrong numbers, when the right number was listed on the form, particularly in light ATF 41F going into effect?

Not currently. That is something I am going to follow up with ATF about. I was alerted that it would likely need to be run through the NFA Branch counsel before I received an answer.

Does ATF prioritize Form 3 transfers? Is there any plans to “auto approve” Form 3 transfers using the eForms system after verifying the information on the form?

As stated earlier, the NFA branch is again prioritizing Form 3s. They are trying to process them within 30 days (that’s the goal). There is no plan for “auto approval”.

What constitutes a “fatal error” on a form?

A few examples I was given were 1) wrong serial number, 2) no serial number, 3) wrong address.

Firearms and Ammunition Technology Division

If you have a sample you want a determination request on prior to SHOT Show 2017, you must submit it to FATD no later than the end of September.

Office of Regulatory Affairs

For those who had questions regarding why comments reflected in the docket for regulatory changes were not all displayed, I learned a few things. First, if the comment contains just vulgarity, it will not be displayed. ATF will retain it and it will likely be subject to a FOIA request, but it won’t be displayed on regulations.gov. They also may be available for viewing in the reading room.

As for the timeline for comments submitted being displayed on regulations.gov, I was told that depending how much workload they had, it could be very quick or take a while.

Itar

DDTC

Unfortunately, the question that most people wanted answered “Do I have to register under ITAR?” is not one that was able to be asked to someone at DDTC who handles registration. However, the guidance that DDTC issued on July 22nd, available here, tells you whether you have to register under ITAR or not. Additionally, the guidance also tells an individual how to inquire with DDTC as to whether the need to register.

 

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FICG Files Comment in Opposition to ATF 29P on Behalf of Dead Air Armament

DA logo

The Firearms Industry Consulting Group, a division of Prince Law Offices, P.C.,  is pleased to announce that it was retained by Dead Air Armament (“Dead Air”) to prepare a detailed filing in opposition to ATF’s Advanced Notice of Proposed Rulemaking (“ANPR”) 29P.  Dead Air has combined the brains and passion of both Mike Pappas and Gary Hughes to bring to the market some of the most innovative and anticipated silencers of the past year.

Because there is a delay in the posting of newly filed comments on http://www.regulations.gov, a copy is available for your viewing here.

An inspection of the docket this morning showed that no other silencer companies have filed a comment in opposition to this ANPR, making Dead Air the first in the silencer industry to take charge in the fight to prevent additional, unnecessary regulations.

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If You Thought ITAR Was Bad…Firearm and Ammunition Manufacturing, Importing (and Gunsmithing) Taxes

Recently, attorney Adam Kraut with Firearms Industry Consulting Group, a division of Prince Law Offices, P.C., blogged about the guidance recently issued by the Directorate of Defense Trade Control (DDTC) relating to its interpretation of what constitutes manufacturing under the Arms Export Control Act (AECA) and its implementing regulations, the International Trafficking in Arms Regulations (ITAR). Although I have blogged about ITAR’s applicability to the Firearms Industry for a long time, including my 2012 article that DDTC was stepping up enforcement of ITAR against the Firearms Industry and thereafter, ATF’s notice to firearm and ammunition manufacturers that they are likely required to register, the Firearms Industry has generally responded in absolute shock to DDTC’s recent guidance that AECA/ITAR regulates the Firearms Industry, even though it has since its implementation in 1976. While some of DDTC’s guidance does go beyond AECA/ITAR, such as requiring gunsmiths to register if they’re merely threading barrels, that is a battle that will need to be fought in court, if the Firearm Industry wants to challenge DDTC.

Nevertheless, there is another, potentially more encompassing law, the Firearm and Ammunition Excise Tax (FAET), which was first imposed by the Revenue Act of 1918. You can find it at 26 U.S.C. §§ 4181-4219 and the regulations at 27 C.F.R. Part 53. It is currently enforced by a separate agency, the Alcohol and Tax Trade Bureau, although referred to as TTB.

So, if you thought it was difficult enough remembering the definition of a “firearm” or what constitutes “manufacturing” under the Gun Control Act (GCA) and now AECA/ITAR, get ready, because FAET’s definition of a firearm and manufacturing is separate and distinct. While a book could be written on the intricacies of FAET, the exemptions, and the exceptions (yes, exemptions are different from the exceptions), this article is merely intended to give the Firearms Industry a heads up that they need to ensure their compliance not just with the GCA or AECA/ITAR, but also the FAET.

The FAET provides that a tax of 10% is due on the sale price for pistols/revolvers and 11% on all other firearms and shells and cartridges. Anyone manufacturing or importing any taxable product must file quarterly with the TTB on its 5300.26 Form (except, you do NOT need to submit a return for periods where no tax is due). BUT, what is a firearm? What are shells and cartridges? And what constitutes manufacturing or importing? And there are exceptions/exemptions, right?

Firearms

As I mentioned about FAET’s definition is NOT identical to the definition found in the GCA. FAET defines a firearms as:

Any portable weapons, such as rifles, carbines, machine guns, shotguns, or fowling pieces, from which a shot, bullet, or other projectile may be discharged by an explosive.

So, if the firearm is not “portable,” it is not taxable; however, pursuant to ATF Ruling 97-2, portable means the weapon can be lifted and carrier by an average person. In that ruling, ATF found that a Model 1919 was portable.

Further, for a firearm to be taxable, it must be complete. Thus, frames and receivers are not taxable; however, selling a firearm in breakdown condition (e.g. all parts present but not assembled) does not exclude it from being a taxable firearm. (Also, don’t think that you can just sell, for example, an AR-15 without a bolt and then, three weeks later, send the customer the bolt, to avoid the tax – REMEMBER, there is a difference between tax avoidance (which is lawful) and tax evasion (which is unlawful)).

Unlike under the GCA, antique firearms ARE firearms and ARE taxable under the FAET and include matchlock, flintlock and perscussion cap firearms. Moreover, unlike the GCA, silencers/suppressors are NOT included under the FAET.

Oh and for the real kicker? Pursuant to ATF Ruling 94-6, a manufacturers own use of a firearm it manufactured for purposes of a demonstration results in a taxable occurrence. Moreover, if a manufacturer lends a firearm to a evaluator for review, such constitutes a taxable occurrence.

Shells/Cartridges

Shells and cartridges is defined in the regulations as:

Any article consisting of a projectile, explosive, and contained that is designed, assembled, and ready for use in firearms, pistols or revolvers.

Like with firearms, all components of the ammunition must be present. Hence, blank ammunition with no projectile is exempt. HOWEVER, the sale of un-assembled ammunition kits (e.g. all components present), less than lethal ammunition, marker ammunition with plastic projectiles…etc are all taxable.

Like with firearms, if a manufacturer uses its own ammunition for a demonstration or its own business purposes, it must pay the applicable tax.

Who’s a Manufacturer?

Of course, we also have to define what constitutes a manufacturer, since I already told you that it was not consistent with the GCA or AECA/ITAR. Under the FAET, a manufacturer is defined as:

Any person who produces a taxable article from scrap, salvage, or junk material, or from new or raw materials by processing, manipulating, or changing the form of an article or by combining or assembling 2 or more articles.

Hence, it is not just the manufacture of a new firearm from raw materials that results in the manufacture of a firearm; but rather, it also includes the change in the form of the firearm (or ammunition). Under Revenue Ruling 69-325, it was held that the converting of military rifles into “sport-type” rifles by removing the wooden stock, cutting off the end of the barrel and installing a new front site constituted a change in form of the firearm and resulted in the manufacture of a firearm, for purposes of the FAET.

In this vein, TTB on its publication Gunsmith Information declares that merely “[c]utting off part of the barrel of a firearm is, of itself, an act of manufacture.” (see page 2 of the publication).

However, there can be a distinction between a fabricator and a manufacturer (resulting in a drastic tax liability difference), depending on who owns the materials at the time the firearm or ammunition is to be manufactured. In some occasions, the customer, if he/she provides all the materials, can actually constitute the manufacturer of the firearm/ammunition under the FAET.

Who’s an Importer?

Of course, this article wouldn’t be complete without defining an importer, since they too come under the FAET. An importer is defined as:

Any person who brings a taxable article into the U.S. from a source outside the U.S.

Generally, the FAET focuses on who arranges for the article to be imported as a principal, not the agent.

Exemptions and Exceptions?

All the exemptions and exceptions under FAET are too numerous for this article but some of the more important and applicable ones are:

  1. Purchase by specifically enumerated military departments using appropriated funds (be cautious, not all military departments are enumerated);
  2. Sales to state or local governments (including Indian Tribal Governments and the United Nations);
  3. Sales to non-profit educational organizations (see 26 U.S.C. § 170(b)(1)(A)(ii) for a definition)
  4. Firearms subject to the National Firearms Act, where the tax is paid (be cautious SOTs, as your SOT fee is not the payment of the tax for a particular firearm. Accordingly, in some occasions, it may make more sense to pay the manufacturing tax ($200.00) on the manufacture of an NFA firearm rather than pay the 11% tax);
  5. Manufacturers of less than an aggregate of 50 pistols. revolvers, or firearms during a calendar year (this does NOT apply to manufacture of shells or cartridges); and
  6. Personal use is exempted, per 27 C.F.R. 53.112(b).

The Good Aspect to FAET?

The only good thing about FAET is that all tax revenue goes into a trust fund, which can only be used for wildlife restoration and hunter safety training.

Confused?

If you’re still confused about the FAET’s application to your situation or need to submit a request for determination to the TTB, we are here to help. Give us a call at 888-313-0416 or send us an email at Info@PrinceLaw.com.

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