there is a firearm (rifle) from WW1 that does meet that criteria and the magazine is in between a fixed and a detachable one. Its magazine spring is loose and when you pull the magazine out it will dump all the ammo left in it. But soldiers carried full magazines and instead of loading the one in the firearm, swapped the fixed magazine out. It did not need a tool. Its like an SKS type magazine that didnt hinge in the front.
The regs define action as:
While the magazine spring and follow facilitate the loading, they do not aid in the firing.
The regs define action as:
"Action" means the working mechanism of a semiautomatic firearm, which is the combination of the receiver or frame and breech bolt together with the other parts of the mechanism by which a firearm is loaded, fired, and unloaded.
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