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.

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The key word here is “reasonable”.
And does not apply to many (most?) on the left.


I am a gun manufacturer! I “manufactured” a short barreled rifle after I got my tax stamp back from ATF. I bought a CZ factory folding stock and slid it on the back of my Scorpion pistol. I had a guy at the flea market laser engrave my name and city and state on the plastic receiver above the serial number CZ had there. Know what I did next? I put a vertical fore grip on the bottom rail! Ha, ha, ha, ha to all you plebes with folding “braces” and angled fore grips. I manufactured a short barreled rifle!… Read more »


Yes, lots of lawyers fees for sure. That said it’s another example showing that the paradigm of “ government control of access to firearms” is dying if not already dead. People need to start thinking about what that means for all sides in the gun control debate. We have already seen attacks on ammunition, EPA concerns about firing ranges other backdoor means of limiting 2A rights. If you are pro gun control but it’s physcically no longer possible to control access, what are your real goals? Is there a win win for both sides? Paradigm shifts offer opportunities and threats… Read more »

Greg K

Here in WA St., they used the Dept. of Commerce or the Dept. Health to declare lead a safety issue at gun ranges.


“Gun Control” is only about one word, and it’s not “Guns”.

Wild Bill

The BATFE needs to go. The National Firearms Act and the Gun Control Act need to go. The Second Amendment is a Constitution level control on all levels of government. The Second Amendment expresses the founders intention to fill the legal field regarding arms. The Founders preempted future Congresses, presidents, bureaucrats, the states, counties and cities, and the entire judiciary from making laws, rules or regulations regarding arms.
Diminishing our Civil Rights only takes our control off of government. Government is getting more powerful, more greedy, and more corrupt.

So Sueme

Yeah, Okay…but it’s not the IRS you need worry about in this case…it’s the Bureau of Alcohol, Tobacco, Firearms and Explosives.


I think you’re missing the point. The standard the ATF uses for determining whether or not an FFL is required to make or sell firearms or ammunition is if the person is “engaged in the business” of doing so. The definition of “engaged in the business” set forth in Title 18 USC §921 (a)(21)(A) requires, in part, that said person operate “…with the principal objective of livelihood and profit…” A person not meeting that test can’t meet the definition of “engaged in the business” and this can’t be required to obtain an FFL per the GCA. A 501(c)3 non-profit doesn’t… Read more »

William Flatt

The fact remains, GCA ’68 is a total infringement on the 2nd Amendment and MUST be repealed! States must pass their versions of the model Firearms Freedom Act so that peaceable citizens are at liberty to make, own, use, and carry the firearms they have built/created. Is there any way that President Trump could be persuaded to champion a repeal of GCA? Only time will tell. He will need help, though, we must vote OUT every Democrat & RINO (Republicans In Name Only) that we can. Then a pro-2A majority can push the legislative relief we need. We already have… Read more »


This effectively repeals the GCA.

Missouri Born

I have a feeling they will spend lot’s of dollars on lawyers to stay out of jail because the gun haters will be after them.


Given that this project is predictaded on the federal government granting non-profit status, there is obviously no intent to break the law.
Last time I checked, no reasonable prosecutor would levy charges in the absence of clear intent.