I found a copy of the text of the 1999 letter which contradicts the 1981 letter:
I Emailed my (Republican Pro GUN) Senator to see if he would see about getting a favorable resolution to the contradiction)
DEPARTMENT OF THE TREASURY
BUREAU OF ALCOHOL, TOBACCO AND FIREARMS
WASHINGTON, DC 20226
MAR 12 1999
903050:RDC
3311
Dear :
This refers to your letter of January 4, 1999, In which you inquire
about the legality of purchasing a replica shoulder stock for your
Canadian Inglis No. 1 Chinese contract Browning Hi Power 9mm semi
automatic pistol having a serial number that begins with the letter
"CH".
27 Code of Federal Regulations (CFR), Part 178, section 178.11,
defines the term "curio or relic" as firearms which are of special
interest to collectors by reason of some quality other than is
associated with firearms intended for sporting use or as offense or
defensive weapons. To be recognized as curios or relics, firearms
must fall within one of the following categories:
(a) Firearms which were manufactured at least 50 years prior to the
current date, but not including replicas thereof;
(b) Firearms which are certified by the curator of a municipal,
State, or Federal museum which exhibits firearms to be curios or
relics of museum interest; and
(c) Any other firearms which derive a substantial part of their
monetary value from the fact that they are novel, rare, bizarre, or
because of their association with some historical figure, period,
or event. Proof of qualification of a particular firearm under
this category may be established by evidence of present value and
evidence that like firearms are not available except as collector's
items, or that the value of like firearms available in ordinary
commercial channels is substantially less.
- 2 -
Mr.
The Bureau has previously determined that the Canadian Inglis No.
1 Chinese contract Browning Hi Power 9mm semiautomatic pistol
accompanied by an original Canadian manufactured detachable wooden
holster/shoulder stock is a "curio or relic" as defined in 27 CFR,
Part 178, section 178.11. This specific pistol and shoulder stock
combination has been determined to be primarily a collector's item
and not likely to be used as a weapon. The combination is
therefore removed from the provisions of the National Firearms Act
(NFA).
A Canadian Inglis No. 1 Chinese contract browning Hi Power 9mm
semiautomatic pistol with a compatible reproduction
holster/shoulder stock is still subject to all of the provisions of
the NFA. Individuals desiring to acquire a reproduction
holster/shoulder stock for their Canadian Inglis No. 1 must first
submit and have approved ATF Form 1 "Application to Make and
Register a Firearm" and pay the applicable $200 making tax.
We trust that the foregoing has been responsive to your inquiry.
If we can be of any further assistance, please contact us.
Sincerely yours,
[signed]
Edward M. Owen, Jr.
Chief, Firearms Technology Branch