The November 2009 FFL Newsletter (found at http://www.nfaoa.org/documents/ffl-newsletter-2009-11.pdf) states that a "Pistol Grip Firearm" (generically, a pump action shotgun with a pistol grip) is not a "shotgun." An October 27, 2010, letter from the Firearms Technology Branch ruled that such a firearm, with a 17" barrel and 26-1/4" overall length, was not subject to the National Firearms Act.By ATF definitions, they would be classified a "any other weapon" along the lines of a sawed off shotgun.
S.T. 779 further states that "The test described by the [National Firearms] for determining whether a particular weapon comes within the classification of 'any other weapon' . . . is not the length of the barrel, but whether the weapon is capable of being concealed on the person," and that the foregoing gun met the definition of "any other weapon" under the NFA.The potential legal ramifications come up if the use of such a weapon is prosecuted and then the precedent is set.
There are millions of such "pistol grip firearms" that have been lawfully owned by millions of law-abiding citizens for many years, and they are manufactured by a variety of firearms manufacturers. If these firearms were ruled to be NFA firearms, they would be instantly and involuntarily converted into illegal contraband. Moreover, under current law, there is no legal mechanism to enable their continued legal possession except by (1) registering them as NFA firearms during an amnesty established by the Attorney General, or (2) a change in the NFA law, which must be enacted by the Congress and signed by the President.Something to think about.