Company Aims to Bypass ‘Build Party’ Restrictions by Offering Nonprofit Classes

Time was you didn’t need permission. (Harpers Ferry Armory by Jarek Tuszyński: Creative Commons Attribution 4.0 International)

U.S.A. – -( A gun parts entrepreneur believes he has found a way around restrictions that shot down so-called “build parties” in which machine shops would be used to convert “80% lower receivers” into firearms.  Stephen Bozich, has created Armed & Safe Firearm Training Academy, and proposes conducting classes as a way around government-defined “engaged in the business” proscriptions.

“This is the critical standard the ATF uses to determine if an entity (be it an individual, a corporation, or anything in between) requires an FFL,” Bozich says,

“[I]t is important to remember that ATF has consistently stated that it is lawful for an individual to manufacture his/her/its own firearm, without need to mark it, provided that he/she/it has no intent to sell or distribute it,” firearms attorney Joshua Prince wrote in January, 2015, after the Bureau of Alcohol, Tobacco, Firearms and Explosive issued a new rule.  ATF Rule 2015-1, put the kibosh on the parties:

Held, any person (including any corporation or other legal entity) engaged in the business of performing machining, molding, casting, forging, printing (additive manufacturing) or other manufacturing process to create a firearm frame or receiver, or to make a frame or receiver suitable for use as part of a “weapon … which will or is designed to or may readily be converted to expel a projectile by the action of an explosive,” i.e., a “firearm,” must be licensed as a manufacturer under the GCA; identify (mark) any such firearm; and maintain required manufacturer’s records.

Held further, a business (including an association or society) may not avoid the manufacturing license, marking, and recordkeeping requirements of the GCA by allowing persons to perform manufacturing processes on blanks or incomplete firearms (including frames or receivers) using machinery, tools, or equipment under its dominion and control where that business controls access to, and use of, such machinery, tools, or equipment.

Bozich believes he’s found a workaround.

“I started a company called Bare Arms ( that sells 80% kits,” he told AmmoLand Shooting Sports News. “Since nothing Bare Arms sells is regulated by the Gun Control Act, no FFL is required.

“I hired a lawyer to assist me in drafting an application for 501(c)3 status for a non-profit organized for the purpose of firearm education and safety,” Bozich continued. “In the application, we asked the IRS if giving build classes, using the tools and equipment under the control and dominion of the non-profit constituted a legitimate (and thus recognized) non-profit activity. They said ‘yes.’

“Armed & Safe is a 501(c)3 non-profit organization dedicated to firearm education and safety, which will offer, among a plethora of programs, seminars, and workshops, classes on how to turn an 80% into a 100% using the equipment of the non-profit,” Bozich concluded.

It’s an interesting concept, and from an IRS perspective is no doubt compliant with tax rules. Whether ATF will consider it compliant with its rules and with the Gun Control Act of 1968 remains to be seen.

About David Codrea:David Codrea

David Codrea is the winner of multiple journalist awards for investigating / defending the RKBA and a long-time gun owner rights advocate who defiantly challenges the folly of citizen disarmament.

In addition to being a field editor/columnist at GUNS Magazine and associate editor for Oath Keepers, he blogs at “The War on Guns: Notes from the Resistance,” and posts on Twitter: @dcodrea and Facebook.