ATF's determination letter states that once the lower has been configured as a rifle, or has been marked as a rifle on the 4473, it can never be a pistol....
now assuming the 4473 form is checked as a receiver, federally the burden is on the feds to prove that it has been previously configured as a rifle.
if it has been configured as a rifle, according to the ATF, it can never be a pistol and manufacturing it into a pistol will actually make it an SBR...
As far as DROS..
ATF has also ruled that CA DROS has no effect on what the ATF defines each firearm.
so theoretically, if you 4473 a receiver as a receiver (other)... and never build it... then move out of California, you could then build it as a pistol.
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