The RPD light machine gun was developed by Russian weapon designer Vasily Alexseyevich Degtyarev and adopted by the Red Army during 1953. The Ruchnoy Pulemyot Degtyaryova RPD LMG was unique because it fired the then new mid-range 7.62x39mm cartridge, with a muzzle velocity of 2,410 feet per second. The weapon became well known in the West when it was fielded with devastating effect against U.S. and friendly forces during the war in Vietnam. The RPD was manufactured in China, Poland, Egypt and North Korea. Long obsolete in the Russian army, the RPD was replaced in Soviet service in 1961 by the magazine-fed or drum fed RPK, a heavy-barrel version of the stamped sheet-metal AKM assault rifle. However, the RPD continues to see service in many third-world countries and in the armies of some former Warsaw Pact members.

The belt-fed RPD light machine gun is gas operated, fires from an open bolt and is full-automatic only. The weapon has an overall length of 40.8 inches (1036.20mm) and weighs 15.6 pounds (7.1) kg unloaded. The chrome-lined four-groove barrel is 20.5 inches (520.7mm) in length. A folding bipod is permanently attached to the end of the barrel. Although the published cyclic rate is usually quoted from 650 to 750 rounds per minute, the actual cyclic rate is closer to 800 to 900 rounds per minute.

Although a very good and reliable design, The Soviet conceived RPD light machine gun did have a few shortcomings. These included a gas regulator system that was difficult/impossible to adjust in the field when fouled, and a permanently attached barrel that is threaded into the receiver and pinned in place, and thus cannot be replaced by the soldier in the field. The design requires the operator to be trained to fire short bursts so the barrel is not overheated. The fixed barrel was a compromise to keep weight to a minimum, and the design simple. The RPD also lacks a carry handle, making it difficult to pick up and move quickly and awkward to carry over any distance, particularly if the weapon is hot from firing.

RPD link belts are very similar in design to the belts fielded during World War II by the Germans for their MG34 and MG42 light machine guns. The non-disintegrating RPD belts were manufactured from stamped steel in 50-round lengths. The first belt has a feed tab, and the last link of the belt has a small tab that slides into a slot in a second belt, inserting a cartridge in the link connects the primary and secondary belts together. The RPD belts are a push-through design; the links, which are open at the bottom, are connected together by a small spiral spring. Each link has a front tab the rides over the feed tray’s cartridge guide. The original Soviet design has a rear tab that aligns and secures the cartridges by snapping into the cartridge’s extractor groove. The Soviet design caused feeding problems if the belts were not fed from the drum. Without the drum the belts would be subjected to vibration and twisting and as a result the cartridges would become misaligned in the belt. While the Hungarians fielded the RPD, they did not manufacture the weapon; however they did re-design the links to be more reliable. The solution was simple. Instead of using a rear tab in the extractor slot they used a tab with a 90-degree angle that fit over the base of the cartridge case. Most countries manufacturing RPD belts copied the Hungarian pattern. The Chinese manufactured the Hungarian style links, but in 25-round lengths, for their RPD copies the Type 56 and Type 56-1.

The two 50-round belts were designed to be fed from a stamped steel drum magazine that attaches to a bracket, which is riveted to the receiver on early models, on later models the drum bracket can be rotated to serve as a dust cover. The drum has a hinged cover and a latch to secure the lid to the drum body. The drum serves only as a container to hold and feed the belts, there is no type of driving mechanism inside. The RPD can be fed the belts without the drum, although they may need to be supported by an assistant gunner to avoid stoppages.

The East German Belt Loader
der Gurtfullvorrichtung GV-64

The standard operating procedure for most countries fielding the RPD light machine gun was to recover spent belts from the battlefield for reuse. However, the only known belt loader for the RPD was designed and built by former Soviet ally East Germany during the 1960s. Because of several different caliber machine guns were in use by the East Germans, the ingenious, but complex, hand-cranked machine was designed with the capability to service a variety of belts. Through the use of adapters the loader could load, or unload 7.62x54R belts for the SG-43 and PKM, 7.92×57 for the MG34 and MG42, as well as 7.62x39mm RPD belts, AK box magazines and 75-round RPK drums. The adapters were marked 7.62 mR mit rand (with rim) and 7.92. For RPD links the adapters were marked; 7.62 sG for Sowjetische (Soviet) for the original Soviet links, 7.62 uG for Ungarisch for the Hungarian pattern links and M43 M for AK box magazines or 75-round drums. The machine can also be set up to load tracer or other specialty cartridges in ratios of 2 to 1 or 5 to 1. After the caliber-particular adapters are installed in the machine, loose rounds can be manually placed into a curved feed chute, or the loader can be fitted with a large caliber-specific circular tray designated as the GFV-64 Zubehor (accessory) Z-1 and Z-2. Large quantities of loose cartridges can be dumped in the roller chain-driven circular tray, which with each rotation of the crank handle, are automatically aligned and
fed into the loader.

A New U.S. Made Belt Loader

Unfortunately, there are not many transferable RPD light machine guns in the NFA registry. However, some parts kits have been imported, and BATF approved semiautomatic receivers have become available as well as complete RPD-semiautomatic rifles. Drums and belts are fairly common and inexpensive. One problem with the RPD is that the steel non-disintegrating belts are very difficult and time consuming to load by hand. The only known military issue belt loaders are the aforementioned machines produced by the East Germans, and they are quite rare, and if found can be very expensive. It would be cost prohibitive for anyone to copy and manufacture the German loader today. Fortunately, there are many innovative individuals and companies out there that see a need for a product, and have the resources to design, manufacture and market such products. One such item is a simple belt loader for RPD belts, well not quite as refined or efficient as the original East German loader; it is available, affordable and does the job.

The patent-pending RPD belt loader was designed and manufactured by Kendall Ordnance LLC of Copley Township, Ohio. The loader base is made of aluminum and is carefully machined to accommodate both Hungarian and Soviet pattern RPD link belts. The steel handle is designed with just the right amount of offset to press the cartridges into the links. The loader is very simple to use; simply insert a belt and lay cartridges on top of the open side (bottom) of each link. The aluminum base is designed to help hold the cartridges in place while downward pressure is applied to the handle, pressing the cartridges into the belt. New links can be a little more difficult to load than used ones, requiring more pressure be applied to the handle. Loading can be eased by loading fewer rounds each time.

RPD loaders courtesy of Dan Lyons collection.

Sources:

RPD loaders, Kendall Ordnance LLC
Website: kendallordnance.com
Email: walkdead19@kendallordnance.com

DSA Arms Inc.
RPD semiautomatic receivers, rifles, links, drums and parts.
Website: www.dsarms.com
Phone: (847) 277-7258

SARCO
RPD Parts, links and drums
Website: www.e-sarcoinc.com
Phone: (610) 250-3960

RTG Parts
RPD Parts, links and drums
Website: www.robertrtg.com/store/pc/home.asp
Phone: 623-362-3459

This may be the first piece of armor that every man can put to good use. We all don’t find ourselves in the path of incoming gunfire or breaching buildings in search of terrorists or hostage-takers, but may indeed find ourselves putting our bodies at imminent risk of damage, or at least discomfort. Motorsports, team sports, or some careers may ask that we take a bump here or there. Imagine the level of protection that comes from a “cup” made of ballistic material- capable of stopping a bullet. Yes, NUTSHELLZ makes a bulletproof cup. They were initially developed for the armed professional (police, SWAT), but have also found favor with athletes and soldiers. The NUTSHELLZ cup is more pliable and ergonomic than the typical unit found in a sporting goods store. This cup features a ventilated rubber rim. An added benefit to donning the NUTSHELLZ is the tremendous confidence that comes from knowing that your important bits have never been safer. This elevated confidence level has been shown to improve performance on the job and on the field by reducing an individual’s inhibition and restraint in a physically demanding scenario. NUTSHELLZ are available in level 1 (Kevlar) and level 2 (Spectra) ballistic protection. Injuries to the genital region of the body and complications thereof can be very severe, and the ill effects of injury can be life-long. NUTSHELLZ offers the best protection. And yes, live-fire demonstrations have been conducted on human test subjects. SAR does not recommend live fire testing of this product.

NUTSHELLZ. www.armorednutshellz.com

CCA ANNOUNCES NEW NON-NFA CIVILIAN RONI PISTOL CARBINE CONVERSION

CAA, developers and manufacturers of advanced battle-tested firearms accessories, is proud to announce the RONI Civilian pistol carbine conversion for the GLOCK 17* is now shipping to distributors and dealers across the country. The RONI Civilian is not NFA regulated, which means, you can own this RONI without the extra NFA paperwork, long wait times and additional taxes. The RONI-C-G2 model is built on a conventional style stock with many of the features that RONI fans have come to know and appreciate, such as quick lock for easy installation, and a multiple rail system that allows for easy attachment of lights, lasers and night vision devices (NVD). The Civilian aprovlso features an innovative muzzle shroud and a 16” barrel. The trigger guard ides additional safety, especially during tactical moves. The collapsible buttstock has an adjustable cheek piece and a magazine holder that allows the user to quickly access and change magazines effortlessly. Optional flip up front and rear sights are also available (FRS/FFS). Visit your local dealer and see the RONI Civilian for yourself! This is a “MUST HAVE” accessory for every Glock 17 owner! Made from polymer and aluminum, the Civilian RONI weighs just 57 ounces and is 30.3 inches with the stock extended and just 27.2 inches with the stock collapsed. At this time the new Civilian RONI is available only for the GLOCK 17. You can get more information by visiting www.ccagearup.com.

MIDWAYUSA INTRODUCES LIGHTWEIGHT TACTICAL SHOOTING MAT

MidwayUSA is pleased to announce the latest addition to their shooting gear lineup – the MidwayUSA Lightweight Tactical Shooting Mat. The MidwayUSA design team set out to make a lightweight tactical mat that could roll-up into a compact design, and that’s exactly what they did. With valuable input from customers, and a little R&D, the MidwayUSA Lightweight Tactical Shooting Mat is sure to impress. Features include a data card pocket, 5 millimeters of closed cell foam padding, four corner tie downs, and best of all, a water resistant non-skid bottom. The exterior is constructed of 400D PVC coated polyester fabric on top, and 1200D PVC coated polyester on part of the bottom, making this mat highly abrasion resistant and perfect for maintaining a solid prone position. When not in use, the mat conveniently stores in its included MOLLE compatible pouch. Unrolled, the mat is 69” long and 30-1/4” wide; rolled dimensions are 15” x 8”. The Midway USA Lightweight Tactical Shooting Mat is available in a variety of colors including black, coyote and olive drab. Learn more about the MidwayUSA Lightweight Tactical Shooting Mat at www.midwayusa.com.

SIG ELECTRO-OPTICS UNVEILS NEW TANGO6 RIFLESCOPE

SIG SAUER, Inc. and SIG Electro-Optics is pleased to unveil the TANGO6 5-30x56mm tactical riflescope with patented LevelPlex technology. This scope introduces a new degree of long-range accuracy to any firearm by allowing the shooter to virtually eliminate gun and scope cant from the shooting equation. Powered by MOTAC (Motion Activated Illumination), LevelPlex appears to the shooter in the form of illuminated arrows on the horizontal axis of the reticle, informing the shooter of firearm cant, direction of cant and severity of cant. The illuminated arrows guide the shooter back to a level hold until the cant is corrected: No more taking your eye off the target to check a level. In addition to on-range use, LevelPlex allows for super-fast and remarkably accurate level scope-to-rail mounting: Level the rifle in a gun vice and simply use LevelPlex to level the scope to the rifle upon setup—no more fumbling with magnetic bubble levels on turrets. The new TANGO6 5-30x56mm with LevelPlex and T120 Turrets offers shooters the ideal high-precision shooting solution and unparalleled technological advancements. LevelPlex allows the shooter to remove unwanted cant from the shooting system to +/- .5° of accuracy, which is 6 times more accurate than a typical bubble level. The T120 high-speed low-profile turrets help the user to quickly dial-in their shooting solution—because time and accuracy always matter. The new scope is fog-proof as well as complete immersion waterproof up to 1 meter. This scope like other Sig optics is covered by the Sig Sauer Infinite Guarantee. They will repair or replace your SIG SAUER product in the event it becomes damaged or defective, at no charge to you. If they cannot repair your product, they will replace it with a product in perfect working order of equal or better physical condition. It doesn’t matter how it happened, whose fault it was, or where you purchased it. For more information go to www.sigsauerinc.com.

NEW NAS3 TWO-PIECE BRASS SHELL TECHNOLOGY REVOLUTIONIZES BRASS

Ever since the brass cartridge case was invented it has pretty much remained the same. Now there is a revolutionary new brass cartridge case that will become the future of ammunition. The new casings are not brass at all but rather a nickel alloy stainless steel cylinder that is mated to a nickel-plated solid aircraft-grade aluminum base. The stainless cylinder is less abrasive than brass, self-lubricating and corrosion resistant. Stronger and more elastic than brass it spring back to its original shape when fired. The aircraft-grade aluminum base will not abrade, clog, foul, or damage breach or ejector mechanisms. The base will not “balloon” when fired from unsupported chambers such as in Glock or some submachine guns. The new “brass” will accept any type of existing 9mm bullet. Now some of the revolutionary features. The casings can be reloaded up to 45 times without trimming or any special preparation. They are also magnetic so they can be picked up with a magnet. The casings are half the weight of brass but yet they are twice as strong. The casings are available with custom headstamps and where the base of the case is aluminum it can be anodized in just about any color to help identify different types of ammunition. These casing also eject from the gun cool to the touch! Right now the new “brass” is available only in 9mm but the next calibers out will be .380 and .45 ACP. The company will follow those calibers with rifle cases in 5.56 and 7.62. With this ammo component weighing half as much as brass this author thinks that the military should be very interested in it. One other thing, these casings are cheaper than brass! So far ammunition loaded with these casings have fired in just about every type of firearm with perfect functioning. For more information contact them at www.shellshocktech.com.

TACTICAL WALLS REVEALS THE HIDE-A-MAG

Those looking for an under-desk or counter-top solution to conceal a firearm or spare magazine now have an answer. Any spot measuring 4”x1”x1/4” can be a mounting spot for the TacticalWalls Hide-A-Mag, a magnetic mount that requires no gravity. A rare earth magnet enveloped in an inconspicuous, matte black, durable plastic protects your firearm’s finish while providing more than 35 pounds of retention. Simply attach the Hide-A-Mag assembly to your desired surface using the supplied attachment screws. The companies firearms retention magnets, found within their existing sliding units, brought about several requests from TacticalWalls customers for a high-strength magnet that could be placed at strategic locations in one’s home, vehicle, or work place. They developed the Hide-A-Mag to answer this call and become an inexpensive, yet valuable accessory for those looking for additional avenues to conceal firearms and accessories. Hide-A-Mag is designed to work with most any handgun, shotgun, rifle, or edged weapon as even polymer-framed guns have plenty of steel within. Metal-lined magazines also tuck up and away nicely and simply slide off the Hide-A-Mag’s plastic casing smoothly and quietly when needed. Great for use inside the top of your Tactical Walls Concealment Shelf, under a desk, behind a cabinet, anywhere it fits and can be mounted. Hide-A-Mag can be found at tacticalwalls.com for $16.99. TacticalWalls is a family owned and operated business, based in the Shenandoah Valley of Virginia and their products are proudly manufactured in the United States. Find out more about all of their revolution products at www.TacticalWalls.com.

SAFARILAND EXPANDS PROTECH TACTICAL LINE WITH NEW HARD ARMOR

Safariland HAS JUST announced the expansion of its Protech Tactical X-CAL line of “in-conjunction-with” (ICW) ballistic hard armor plates with the addition of the X-CAL US. Independently tested under the NIJ 0101.04 type III protocol, this special threat plate under 4 lbs. in weight is designed to defeat high-threat rounds and velocities. With an increased availability of the M855/SS109 round in the domestic market, this hard armor plate will fill the product gap for a high-end, lightweight plate that can protect officers at risk of encountering this type of ballistic threat. Developed in collaboration with Hesco Corporation, a world leader and innovator in the design and manufacturing of protective systems, the debut of the X-CAL US plates affirms the partnership’s ongoing dedication to bringing products to market that meet the evolving challenges and threats in military, security and law enforcement environments. An average two pounds lighter than traditional type III rifle threat plates, the X-CAL US minimizes bulk and load-bearing weight to enhance maneuverability. The X-CAL US plate is approved for use with NIJ soft armor packages offered by Safariland, including the Summit SM02 Type IIIA, Xtreme XT03 Type IIIA and Xtreme SX02 Type IIIA. With an impressive low-profile, the X-CAL US plate is just 0.75” thick with protection against numerous threat rounds such as the 7.62mm FMJ (NATO) and special threat rounds such as the 7.62mm x 39mm, 123 gr. MSC and the 5.56mm, 62 gr. (M855)(SS109) at six impacts each. Available in a 10”x12” multi-curve, swimmers cut, the X-CAL US plate is available to order with part number 1190172 at $710.00 ftlineMSRP. For ordering, please contact an account representative or a member of the Safariland customer service team at 1.800.347.1200. For more information, visit www.safariland.com/protech-tactical.

Firearms and Ammunition Excise Tax:

The Basics-Part II

In Vol. 20, No. 7 of Small Arms Review, we published an article on firearms and ammunition excise tax summarizing the articles subject to tax, definitions of “manufacturer” and “importer,” and exemptions from tax. This article builds on the information in Part I and will address how to determine the taxable sale price for firearms and ammunition subject to tax, exclusions from the sale price, and tax-free sales.

I. Statutory and Regulatory Background

Section 4181, Title 26, U.S.C., imposes a tax on the sale by the manufacturer, producer, or importer of pistols, revolvers, firearms, shells, and cartridges. The tax is 10 percent of the sale price for pistols and revolvers and 11 percent of the sale price for all other firearms and shells and cartridges. The Internal Revenue Code (IRC) also imposes excise tax on the lease of a taxable article by a manufacturer or importer (26 U.S.C. 4217) and use of a taxable article by a manufacturer or importer (26 U.S.C. 4218).

II. Filing of Returns and Payment of Tax

When a manufacturer or importer sells a taxable article, tax liability is incurred, and the taxpayer must file a quarterly return with the Tax and Trade Bureau (TTB), Department of the Treasury. Returns must be filed on TTB Form 5300.26, Firearms and Ammunition Excise Tax Return. No return is required for tax periods in which no tax liability is incurred. Payment of tax may be accomplished by sending a check or money order with the return or through electronic funds transfer (EFT). Information on payment via EFT is available on TTB’s website, www.ttb.gov.

III. Tax on Use

In addition to imposing a tax on the sale of firearms and ammunition, the IRC imposes tax on the use of taxable articles by manufacturers and importers. A good example of a taxable use of firearms would be a manufacturer who arms its plant security guards with firearms that it manufactures. ATF issued a ruling in 1994 (ATF Rul. 94-6, available on TTB’s website) holding that a manufacturer who loans firearms to its own employees as demonstration models incurs tax on the use of the firearms. The ruling also held that a manufacturer’s loan of firearms to writers for technical evaluation results in tax liability on the use of the firearms.

Regulations provide that tax liability incurred on the use of taxable articles is computed on the price at which similar articles are sold in the ordinary course of trade by manufacturers. The taxable sale price is computed on the manufacturer’s lowest established wholesale price for such articles in effect at the time of the taxable use. If the manufacturer does not regularly sell the articles at wholesale, the manufacturer must request a constructive sale price determination from TTB. Later in this article we address the information necessary to request a constructive sale price determination.

IV. What is the Taxable Sale Price?

The IRC provides guidance on how to determine the taxable sale price on which the 10 or 11 percent excise tax is based. Section 4216(a) of the IRC states that the “price” shall include any charge for coverings and containers and any charge “incident to placing the article in condition packed ready for shipment.” Section 4216(a) also specifically allows taxpayers to exclude firearms and ammunition excise tax from the taxable price and any transportation, delivery, insurance, and installation charges.

Implementing regulations providing further guidance on charges which must be included in the sale price and those that may be excluded. The following list, based on 27 C.F.R. § 53.91, provides examples of inclusions and exclusions from the taxable sale price:

Charges to be included in the taxable sale price:

• Charges for demonstration or display of the article or sales promotion programs;
• Separate charges for tools and dies used in the manufacture of a taxable article;
• Charges for warranty, if a purchaser is required to pay such charge to obtain the article; and
• Charges for coverings, containers, and packing material, whether or not the charges are identified on the invoice or are
• billed separately.

Charges that may be excluded from the taxable sale price:

• Federal excise tax may be excluded from the taxable sale price. Where no separate charge is made as tax, TTB presumes that the price includes the proper tax, and the proper percentage of the price will be allocated to the tax. TTB regulations (27 C.F.R. 53.92(a)) provides taxpayers with formulas on how to back the tax out of the taxable sale price;
• Transportation, delivery, insurance, or installation charges. Only those charges incurred after shipment to a particular customer begins may be excluded. Costs incurred for the convenience of a taxpayer, such as shipping articles from a port to a warehouse, may not be excluded;
• Certain charges for local advertising (very limited–see regulations in 27 C.F.R. 53.100);
• Charges for extra identical component parts and accessories (i.e., items not designed to be attached to a firearm during use and not, in the ordinary course of trade, provided with firearms at time of sale); and
• The cost of nontaxable articles sold in combination with taxable articles;
• The above inclusions and exclusions from the taxable sale price are covered in detail in TTB’s implementing regulations. Taxpayers with questions about how to calculate the sale price should contact TTB or qualified counsel for guidance.

V. Constructive Sale Price

Rule and regulations governing the taxable sale price are based on the assumption that most manufacturers and importers sell firearms and ammunition through wholesale distributors. In order to ensure fairness and consistency among taxpayers, the IRC has special rules for manufacturers and importers who sell articles at retail, on consignment, or to an affiliated corporation. There is also a “special rule” for sales of articles to retail dealers, but it is limited in scope.

Sales of Firearms at Retail, on Consignment, and Not through Arm’s Length Transactions and at Less than Fair Market Price

Taxpayers who sell firearms or ammunition at retail, on consignment, or who sell otherwise than through an arm’s-length transaction at less than fair market price must use a constructive sale price as the basis for calculating tax liability. “Sale at retail” is defined in the regulations as sale of an article to a purchaser who intends to use or lease the article rather than sell it. “Consignment sale” is defined as an article sold by a person who has the right to sell it and does sell it, but the seller never takes title to the article from the manufacturer. Sales are considered to be made under conditions other than at arm’s-length if one of the parties is controlled by the other or there is common control, whether or not such control is actually exercised to influence the sale price. A sale will also be considered other than arm’s-length if it is made pursuant to “special arrangements” between a manufacturer and purchaser.

Sales at Retail – 75 Percent Rule

A ruling issued by the Internal Revenue Service issued in 1980 held that the constructive sale price for computing excise tax imposed on retail sales of firearms, ammunition, and other taxable articles for manufacturers who do not sell like articles to wholesale distributors is 75 percent of the actual selling price after taking into account the adjustments provided by 26 U.S.C. § 4216(a), unless it can be shown on an industry-wide basis that a lower percentage should apply. Rev. Rul. 80-273, 1980-2 C.B. 315. Taxpayers who are satisfied that 75 percent of the sale price is appropriate may rely on this ruling in calculating their excise tax liability for sales of firearms and ammunition at retail. The ruling makes it clear that once the constructive sale price is determined, no further adjustments (inclusions and exclusions as discussed above) to the sale price may be taken. Taxpayers who believe a lower percentage is appropriate may request a constructive sale price determination from TTB.

Sales Between Affiliated Corporations

The regulations include guidance on determining the constructive sale price for sales of taxable articles between affiliated corporations. 27 C.F.R. § 53.97. The regulations establish various methods for calculating the constructive sale price depending on to whom the manufacturer sells the taxable articles and whether the purchaser is a member of an affiliated group. These rules are complicated and should be reviewed carefully by manufacturers and importers who sell firearms and ammunition to related selling companies.

Constructive Sale Price for Sales to Retail Dealers

Regulations provide a “special rule” for manufacturers and who sell firearms to retail dealers. The regulations provide that if the manufacturer regularly sells articles to one or more wholesale distributors in arm’s length transactions, then the manufacturer may use a constructive sale price for its sales of the same article to retail dealers. The constructive sale price for sales to retail dealers is the lower of its actual sale price or the highest price it sells the articles to wholesale distributors. 27 C.F.R. § 53.96. Manufacturers whose sales practices fit within this regulation may use the constructive sale price for payment of excise tax on sales of firearms to retail dealers without any permission or determination from TTB.

This “special rule” raises the question of manufacturers who sell to retail dealers but have no regular sales to wholesale distributors. The unfortunate answer is that there is no constructive sale price available to manufacturers in this situation. Manufacturers who have no wholesale sales must use the actual price they charge retail dealers to calculate the amount of excise tax they must pay.

Requesting a Constructive Sale Price Determination

Taxpayers who wish to request a constructive sale price determination should send it in writing to TTB’s National Revenue Center in Cincinnati, Ohio. The easiest way to submit the request is via e-mail: ttbfaet@ttb.gov. A request for a constructive sale price determination should include the following information:

• Types of firearms offered for sale or used in the taxpayer’s business;
• Where taxpayer obtains materials and/or parts for firearms;
• Whether the taxpayer holds patents or trademarks for the firearms;
• How customers order or purchase the firearms or ammunition from the taxpayer OR how the firearms or ammunition are used in the taxpayer’s business;
• Whether customers are purchasing the firearms for personal use or for other purposes;
• Whether the taxpayer regularly sells the firearms to wholesale distributors in arms-length transactions; and
• Cost and price information for each model of firearm sold or used including the taxpayer’s cost for parts and materials, taxpayer’s cost for labor, the price charged to consumers (for sales at retail), and the wholesale cost of each firearm. If the taxpayer does not regularly sell the firearms to wholesale distributors, the taxpayer should include the wholesale cost for each model of firearms used by competitors.

VI. Tax-Free Sales

The IRC includes provisions for tax-free sales of firearms and ammunition for the following purposes:

• For use in further manufacture;
• To a purchaser who will resell the article for use in further manufacture;
• For export;
• For sale to the US Department of Defense and military including the Coast Guard;
• To a purchaser who will resell the article for export;
• For use as supplies on vessels or aircraft;
• To state and local governments (Police/LE sales also) for their exclusive use (NOT Federal agencies); and
• For nonprofit educational organizations
• A ruling issued by the IRS in 1976 (Rev. Rul. 76-119) held that a manufacturer’s use of shells and cartridges it manufactured and then used in testing firearms of its own manufacture is use in further manufacture of another taxable article that is exempt from tax. The ruling also held that the sale of shells and cartridges to a purchaser for use in testing firearms of the purchaser’s manufacturer is eligible for tax-free sale under the IRC.

There are hoops that manufacturers and importers must jump through before they are eligible to sell articles tax-free for the above purposes. First, the manufacturer, importer, first purchaser, and second purchaser (if there is one) must register with TTB on TTB Form 5300.28, Application for Registration for Tax-Free Transactions Under 26 U.S.C. 4221. The form must be filed with TTB’s National Revenue Center. All parties will receive a Certificate of Registry and will then be eligible for tax-free sales or purchases. One significant exception to the registration requirement is that State and local governments purchasing articles directly from a manufacturer are not required to register. Manufacturers selling directly to such government agencies must obtain either an exemption certificate or a purchase order that includes all the information required by the regulations.

TTB regulations governing tax-free sales require taxpayers to retain evidence relating to tax-free sales. Such evidence includes, for example, proof of resale for further manufacture; proof of export; exemption certificates; and purchase orders from State or local government agencies.

VII. Conclusion

Part I and Part II of our articles on firearms and ammunition excise tax provide a basic overview of the issues relating to this provision of the IRC. We hope this information is helpful to manufacturers and importers in navigating this very complex area of the law. More information about the tax is available on TTB’s website, by contacting TTB at ttbfaet@ttb.gov, or by calling TTB’s National Revenue Center at 1-877-882-3277.

***The information contained in this article is for general informational and educational purposes only and is not intended to be construed or used as legal advice or as legal opinion. You should not rely or act on any information contained in this article without first seeking the advice of an attorney. Receipt of this article does not establish an attorney-client relationship.

About the authors –

Johanna Reeves is the founding partner of the law firm Reeves & Dola, LLP in Washington, DC (www.reevesdola.com). For more than ten years she has dedicated her practice to advising and representing U.S. companies on compliance matters arising under the federal firearms laws and U.S. export controls.

Teresa Ficaretta is one of the country’s foremost experts on ATF regulations under the Gun Control Act, the National Firearms Act, the Arms Export Control Act and Federal explosives laws. Before joining Reeves & Dola in 2013, Teresa served as legal counsel to ATF for 26 years, followed by two years as Deputy Assistant Director in Enforcement Programs and Services. They can be reached at 202-683-4200.

Manufacturer: J & T Distributing
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Product description: M16 Buttstock Cleaning Kit
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Manufacturer: J & T Distributing
Product name: M16 Castle Nut Wrench, PN AR753N
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Product description: The M16 Castle Nut Wrench is designed to grab the nut at three different points helping to make sure it doesn’t slip off when installing or removing the buttstock castle nut.
MSRP: $ 12.99

Manufacturer: J & T Distributing
Product name: M16 Car Stock Wrench, PN AR753
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Product Description: The M16 Carbine Stock Wrench gives quicker and easier removal, or installation of collapsible stocks. Firmly grasps the receiver extension nut without damage; no need to use a separate breaker bar. Convenient size for carrying in range bag or tool box.
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Product name: M60 E3 Combo Wrench, PN M60101
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Manufacturer: J & T Distributing
Product name: M16 Chamber Brush, PN CJ113
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MSRP: $ 2.99

Manufacturer: J & T Distributing
Product name: M60 Combo Wrench, PN M60100
Website: www.jtdistributing.com
Product description: M60 Combo Wrench
MSRP: $ 13.99

If you are a long time gun enthusiast, as this author is, you have probably owned a virtual gamut of various types and calibers of firearms. I started out owning a .22 rifle, followed by bolt-action centerfire rifles, progressing through all sorts of semi-auto handguns and rifles, then moving on into the Class III realm of submachine guns and heavy machine guns. It seems like the pinnacle of firearms ownership is a full-auto firearm and then on past that is a belt-fed full-auto. In years past if you owned a select-fire weapon whether it be magazine or belt-fed, if you could afford the gun, the price of ammunition needed to feed it should be no problem. At today’s ammunition prices feeding “the beast” is a very expensive proposition. This has made owning a belt-fed gun (either semi or select-fire) out of the range of most shooters. Things have now changed dramatically with the introduction of a new accessory for the AR-15/M-16 series of weapons called the FM-9 from Freedom Ordnance.

The FM-9 is a complete upper receiver unit that drops right onto either a semi-auto AR-15 or a select-fire M-16 series rifle lower receiver. The unit comes complete with everything you need to change either one of these guns into a belt-fed!! It also allows the shooter to be able to actually go out and shoot it regularly without breaking the bank because this new unit is chambered in 9mm! That’s right. It is a drop-in, no gunsmithing unit that allows your mil-spec AR or M-16 to fire disintegrating metal-linked 9x19mm ammunition. With some 9mm ammunition priced at or slightly below the $200.00 per 1000 round price, this is a unit that you can afford to go have fun with. Not only that, the entire unit sells for about the price of a high quality AR style gun. More on that later.

The Freedom Ordnance FM-9 started life as an idea, a 3-D printer and a Tormach CNC Milling machine. Within a few months the designers had some handmade links and the first 3 shots were fired in one of their backyards. Once the initial concept was proven they acquired a 10,000 square foot building to turn into their production facility. Production milling machines, lathes and other machines were ordered and were received and set in place in February of 2015. The design team then worked over 80 hours a week from February to the first of September of 2015 working out any bugs and making sure that they had a product that was perfectly reliable. They also wanted a product that would feed the most popular (and inexpensive) brands of 9mm 115 grain ammunition being produced. They started out testing many brands and ended up finding out that Tula steel case, PMC and Winchester White Box ammunition worked the best and surprisingly were the most inexpensive. The project was kept very tight-lipped until the end of August 2015 when they released a 15 second video teaser on YouTube. The video made the rounds on the popular internet forums where some claimed that it was vaporware or that it might be in production in “a few years”. The company set up a website with a pre-order page accepting orders, but no advance money, and 4 weeks later the first units were shipping. And the rest is, as they say, history. This author respects a company that does business this way instead of accepting money and then taking maybe years to get a new product into production.

As stated before the FM-9 is a complete upper unit. The unit contains the upper receiver and belt feed mechanism, bolt assembly, feed chute, top cover and barrel extension along with the barrel and quad-rail forearm. The unit’s top cover is hinged at the front with a release latch at its rear. This allows it to hinge up and forward just like most other belt-feds. The top cover has a short 6-slot length of Picatinny on its top rear that allows for optic mounting. The forearm also has Picatinny rails at the 3, 6, 9 and 12 o’clock positions. The quad rail’s top rail is extended in height so that it co-witnesses with the rail mounted to the top cover. The rails are all laser engraved with positioning numbers.

The unit’s barrel is entirely free floated and is held into the barrel extension with a quick attach mechanism. The FM-9’s barrel can be quickly removed by the mere push of a release lever just in front of the top cover hinge. You just push the release lever and rotate the barrel about 1/4 turn with its attached handle and pull it forward out of the upper receiver. This works perfectly for changing out a hot barrel or changing out the barrel for one of a different length. Barrels are available in either 11 or 16.5 inches. There is also now a complete pistol upper which features a 6 inch barrel and a shortened quad rail. The unit that I tested came equipped with an 11 inch barrel as I intended on testing it on a select-fire post sample M-16 lower receiver. If you are going to use this size barrel on your semi-auto lower be sure to register the lower as an SBR first.

The FM-9 uses a proprietary bolt and carrier. The unit’s bolt carrier interfaces with the lower receiver’s existing 5.56 buffer and recoil spring without having to swap them out. The rear of the bolt carrier is hollow much the same as a 5.56 bolt carrier but it contains a removable weight. This weight can be installed or removed as needed to tailor the upper to the ammo used. For instance, if you are using hotter ammunition you can leave the weight in to limit cyclic rate as well as eliminating advanced wear in internal parts. The included owner’s manual tells the procedure for doing this based on the ejection pattern of empty brass thrown from the unit. Being able to use everything in your existing lower without having to swap out any parts is a great added feature. The bolt will work in either semi or select-fire guns.

The only other part that is needed to complete the conversion is a block that is inserted into the lower receiver’s magazine well. This block comes with the kit and is inserted from the top of the receiver and locks into place with the lower’s magazine release. Being inserted from the top, this block cannot be accidently dropped out if the shooter hits the magazine release button. This block also houses the ejector. The block also is used to attach a belt bag onto the completed gun. This block as well as a 150 round belt bag and 150 links also come with the unit. The included black Cordura bag holds 150 rounds of linked ammunition and has a zipper along its bottom to allow for easy insertion of a loaded belt. The top part of the bag is riveted onto an aluminum block that features a mating dovetail attachment that locks into the magazine well block. A spring loaded ball detent holds the two blocks firmly together but allows for instant removal of an empty bag and insertion of a loaded bag. The finish on the entire upper, barrel and belt bag attachment block is a hard anodized matte black that matches the finish on almost all of today’s AR style black rifles.

We started the T&E test by naturally having to load ammunition into the links to make the belts. As stated before, the FM-9 is fed with disintegrating metal spring steel links. The links are truly a marvel. Remember you are dealing with a straight walled cartridge case, not a tapered or bottlenecked case like most other belt-fed guns use. The links for the FM-9 are made especially for it. They are not existing links that have been modified to work with this unit. The manufacturers told me that designing and manufacturing the links was almost as big a challenge as building the upper itself. The links are spring steel, parkerized and have a tab that locks into the rim of the 9mm cartridge. I proceeded to load 100 rounds of steel cased Tula 115 grain FMJ ammunition into 2-50 round belts. This was done by hand which can be accomplished, but loading the two belts took me almost 30 minutes. Not only that, both of my thumbs were still sore two days later. I remembered that a friend of mine had e-mailed me a press release about a new product that had just been introduced. It was a belt linker made just for the FM-9. A call to Shepard Bruner at www.triggerjockey.com and one of his Belt Loaders was on its way to me. The loaders that he makes are precision made units machined on CNC equipment. With his loader you can load 10 cartridges into links in about 30 seconds. You merely lay 10 links onto the linker, put 10 rounds of ammunition into milled slots and pull the handle. Do this 5 times and you have a 50-round belt and no sore thumbs.

With a supply of loaded belts I headed to the range. According to the manual that comes with the FM-9, loading the unit is a little different than loading most belt-feds. The manual states that you should load the upper with the top cover closed. It says to lock the bolt open and insert a belt up through the feed chute. Push the loaded belt up until you feel it lock over the belt retaining pawls and seat firmly against the cartridge stop. Give it a gentle pull to ensure that it is locked into place. When you are ready to fire, hit the bolt release or pull and release the charging handle to make the gun ready to fire. The FM-9 unit fires from the closed bolt position.

The upper was installed on a Colt M-16 post-sample lower receiver. The unit fit the lower perfectly with no rattle or play. I started out with the gun on semi-auto and proceeded to fire a few rounds. After about five rounds the gun stopped just as the bolt was pushing a round out of the belt. The top cover was opened, the gun cleared and we started to shoot again this time on full-auto. At about 10 rounds the gun stopped again with the same malfunction as before; a round just partially pushed out of the belt. The gun was cleared and this time a few drops of lube was put on the feed mechanism as well as the bolt. The gun then ran the rest of the belt with no issues what so ever. Not only that, it continued to run several more belts without any malfunctions. The upper unit was shipped to me without lubrication and that coupled with the fact that the links were all brand new must have attributed to the stoppages. The FM-9 unit has, to this date, continued to run perfectly with no malfunctions as long as the recommended ammunition was used. During the testing the ammunition used was Tula 115 grain FMJ and PMC 124 grain FMJ. They both ran without issues but we fired a lot more of the Tula as it was cheaper and more readily available. With Tula ammunition the unit ran like a sewing machine. The cyclic rate was checked with a PACT timer with rate-of-fire option and it averaged 820 rounds per minute as did just about all ammunition that was fired. With a cyclic rate like this and very low recoil you can literally write your name on the target.

I did fire the gun with some of my own 147 grain hollow point reloads. I installed a Thompson Machine suppressor for use with this ammo as it was a subsonic load. As long as velocities were kept in the 1000 to 1050 feet-per-second range the ammunition ran fine and was very quiet. The FM-9 is amazing with a suppressor attached and using subsonic ammunition. You can literally hear the bullets hitting the target as well as the empty brass and links hitting the ground. Empty brass is thrown from the unit at the 3 o’clock position about 6 to 8 feet from the ejection port and the links land about half that far from the gun. The links land in a small pile for easy collection but we always managed to lose a few. This wasn’t considered a big deal as links are only $59.95 per 1000 directly from Freedom Ordnance. The company originally said that the links had a lifespan of about 8 loading and firing cycles but now they have refined their heat treating process and the links now have an almost infinite lifespan. Depending on where you shoot you will probably lose the links before you wear them out. (Just as this article was going to press the author received a new brass catcher from Tactical Brass Recovery for testing. This catcher attaches to the host gun with an American Defense quick attach lever mount that fastens to the right side rail on the quad forearm. The lever is incorporated into a spring loaded, hinge mechanism that allows the entire catcher to pivot out away from the gun to access the charging handle or to clear a malfunction. It has a rigid frame made from lightweight polymer as well as a top pate with holes to see inside. It features a black Cordura catch bag with a zippered bottom for easy emptying and will hold well over 150 brass and links. This unit is extremely well made and never missed catching a piece of brass or a link in over 500 rounds of testing.)

The author mounted a Lucid M-7 Micro red dot sight to the Picatinny rail on the top cover as the FM-9 comes without sights. This little sight is just right for the FM-9. It automatically varies its intensity according to ambient light but can also be user adjusted for 7 levels of dot intensity. It also features an automatic shut down to prevent draining the battery from leaving the sight on. It will run for literally thousands of hours on a single AAA battery. The sight features a 2 MOA dot, is recoil proof (up to .458 SOCOM) and waterproof down to 80 feet. All this in a sight that retails for under $200.00.

The author also got to try out a pre-production model of Crimson Trace’s new LiNQ™ sighting system. The LiNQ consists of an AR pistol grip and a combination light and green laser module that communicates wirelessly. This allows the laser/light module to be placed anywhere on the weapon and be activated by pushing an instinctive activation button mounted in the front of the grip. This is done wirelessly without having to have cables or wires running anywhere on the weapon. There is nothing to catch on or get tangled up with. The LiNQ has 4 modes; light only, laser only, light and laser or laser with strobing light. The unit has a master on/off switch mounted on the side of the grip. It operates on a unique closed wireless system with each unit having an individual wireless signature. That way several operators can use LiNQ mounted weapons without interference from other LiNQ units. The laser is a very intense green that can be seen even in daylight. The white light in the new unit is a very powerful 300 lumens which will light up objects well over 100 yards at night. The unit runs continuously for over 2 hours on two CR2 batteries (one in the grip and one in the light module). The LiNQ gives the user point and shoot capability in any light.

Accuracy from the FM-9 unit was truly amazing. It was sighted in at 50 yards and shot from a shooting bench. Once the optic and the laser were dialed-in the upper would group under an inch on semi-auto. This from a belt-fed gun with a quick-attach barrel is really amazing. In fact, at that same distance entire 50 round belts could be fired into a 6 inch by 6 inch target. The unit is just that controllable.

During the test the gun was carried around quite a bit which began to be a chore. A complete gun with upper installed and with 150 rounds of 9mm ammunition in the belt bag weighs in at 16 pounds. It wears on you packing it around for any length of time. During the testing I had a chance to try out a new sling from Blue Force Gear that appears to be made just for an FM-9 equipped gun. It is their Padded Vickers Sling. The Patent Pending Padded Vickers Sling combines the tactical sling versatility of the Vickers Sling with the added comfort of a padded rear section. The 2” wide inline pad doesn’t move up or down the sling and is made from closed cell foam that won’t separate or gain water weight. The front section, with the Quick Adjuster, allows the user to instantly shorten or lengthen the sling for any mission. It allows very quick transitioning from a “hands-free” carry to a shooting position with a simple pull of the Adjuster. This sling is the most comfortable, easy to adjust sling this author has ever had a chance to use. It is outstanding and comes in two hardware variations; metal or nylon.

In conclusion, the FM-9 upper is one serious piece of equipment. I would not hesitate to recommend it to a police tactical unit or a VIP protection detail as it has shown outstanding reliability other than the first two hiccups when the unit was fired without any lube. That said, in subsequent tests after the upper was throughly cleaned it then ran fine without any lubrication whatsoever. Maybe two failures were even ammo related. Whatever it was, it never happened again in over 1000 rounds put through it.

By the way, the unit was not cleaned until after about the first 500 rounds were put through it. Even then the only thing done, was the top cover was opened up and the feed mechanism was swabbed out with some RamRodz swabs. Then the gun was put back into action. While I’m on the subject of cleaning, the unit is a pleasure to clean instead of a chore. The top cover and the feed block are held in place by a detent pin that can be easily pushed out with the tip of a cartridge. This allows the top cover and feed block to both be removed from the unit for cleaning. This coupled with a quick detach barrel and a bolt that is removed the same way a standard AR bolt is removed, makes the entire unit very easy and quick to clean. In fact, I merely dropped the parts in an ultrasonic cleaner for a few minutes and they were as clean as when they were new.

This author would be hard pressed to not recommend the FM-9 unit to anyone with an AR-15 or M-16 rifle. It is an accessory that is extremely well built, runs just as promised right out of the box and is reasonably priced. With an introductory retail price of just $1895.00 it is by far the most inexpensive way to own a belt-fed!

Freedom Ordnance
www.freedomordnance.com

Lucid
www.mylucid.com

Crimson Trace
www.crimsontrace.com

Blue Force Gear
www.blueforcegear.com

TriggerJockey
www.triggerjockey.com

Tactical Brass Recovery
www.tacticalbrassrecovery.com

The Global War on Terrorism has shown some very interesting trends in small arms for the United States. The full size M16-series rifle has for the most part taken a back seat to the lighter and more compact M4 carbine. There is no doubt that the shorter carbine is easier to maneuver in and out of vehicles and is better for close quarter battle. There is always an exception to the rule and that is the Marine Corps. They have chosen to keep the full size battle rifle and have limited use of the M4 carbine. By tradition the Corps has always been prideful of their marksmanship skills and the 20” barrel provides additional range where their skills can truly shine.

The M16A4 (NSN 1005-01-383-2872) was a direct descendent of the advancements of the M4 carbine. The Marines were the driving force for the M16A2. To go along with their tradition of marksmanship the complex rear sight, adjustable for windage and elevation, was developed. Oddly enough, this sight was quite expensive and the Marines were the only branch that ever trained on its use and shot far enough to make it beneficial. The Army shot basically to 400 yards and that was it while the Marines shoot out to 600 yards. The Marines were also responsible for the infamous 3-round burst mechanism which would haunt the American serviceman until the more recent M4 Product Improvement Program where the burst was finally removed and the automatic setting restored. The burst mechanism has truly been mind boggling. The M16 was developed during the war in Vietnam to significantly increase the firepower on the individual level and to match the firepower of the intermediate caliber AK47. It did just that. Then the M16A2 comes along and now the firepower on the individual level was reduced. The US government was the only customer Colt had ever order a rifle with a BURST setting. Export rifles were most always shipped with the automatic configuration.

In the interim was the ACR or Advanced Combat Rifle program where the US government was looking for a potential replacement for the M16A2 rifle. The most significant goal was to increase hit probability. The Colt entry would use a flat top upper receiver which you could use iron sights provided on a removable carrying handle or mount an optic directly to the receiver and have the optic in line with the shooter’s eye. Mounting an optic on a fixed carrying handle was quite uncomfortable due to how heigh the optic sat on the carrying handle. However this dovetail had some inherit flaws. First the slots in the dovetail were extremely thin. In fact, Richard Swan stuck a pencil through the slot into the inside of the receiver! Second was the stop notches were rounded at the bottom. These issues were not corrected on the ACR but would be addressed on the Mil-Std-1913 rail.

The flat top upper receiver of the M4 with the Mil-Std-1913 rail was truly a game changer and offered an epic degree of adaptability to the M4. Prior to 9/11, almost all rifles in the US arsenal were fixed sight battle rifles. The Canadian Army was the first to pioneer the standardized flat top upper receiver for general military use. They developed their own “Weaver Rail dovetail” for mounting optics. The Canadians moved forward with their ELCAN optics and became the first nation in the world to give every soldier a magnified optic. This also took advantage of the inherent accuracy of the M16 weapons platform. The new family of Canadian weapons created were the C7A1 and the C8A1 family of rifles. US military developments were to follow. It was found that the Weaver rails, although good were not uniform. What was needed was a standardized dovetail which would be accurate and durable. The same man who assisted the Canadians with their flat top rail would go on to help the American government. Mr. Richard Swan of ARMS, Inc is the father of the Mil-Std-1913 rail. When broken down, the Mil-Std-1913 rail has basically three inventors. First is the actual upper receiver with a dovetail, this was designed by Henry Tatro at Colt in the 1970’s. The dovetail itself was designed by Weaver. The final standardized dovetail was done by Richard Swan. Oddly enough the rail is referred to by many as the “Picatinny Rail” named after the Picatinny Arsenal. Picatinny Arsenal had nothing to do with the design of the rail, they were just the project manager. The XM4 would be developed with a standard M16A2 fixed carrying handle with the fully adjustable rear sight for windage and elevation but the final M4 would use the new Mil-Std-1913 flat top upper receiver.

Colt would go on to adapt the M16A2 to the flat top configuration. The prototype was the M16A2E4 which would be type-classified the M16A4. Government drawing number 12973001 and Colt model number R0945. The stop notches on the rail would be changed to a much more durable and reliable square configuration. Unlike all previous designs by anybody, the rail now had final standardized dimensions. Now mounts could be uniformly made to mate with the dovetail. We now have the Mil-Std-1913 rail. The rifles were provided with a detachable carrying handle with the fully adjustable A2 sights. Due to the available dimensions, the rear sight could only be calibrated to 600 meters instead of 800 meters.

The M16A4 as of July 29, 1997 has officially replaced the M16A2 as the standard issue combat rifle for the United States Army and Marine Corps. They will no longer procure any M16A2 (fixed carrying handle) rifles. Colt’s Manufacturing Company, Inc was awarded a contract (DAAE20-98-C-0119) for $6,371,568 to supply the U.S. Government with just over 32,000 M16A4 rifles and was completed and the M16A4 rifles were delivered in the spring of 2001. Colt has manufactured numerous M16A4 rifles for the United States Government but the vast majority of M16A4 rifles have been manufactured by FNMI.

Initial rifles were produced with standard A2-style handguards and removable carrying handles. The rifle retained the BURST setting of the M16A2. With the exception of the upper receiver and detachable carrying handle all other components of the M16A4 remained compatible with the M16A2. With the adoption of the SOPMOD accessories for the M4, the M16A4 would follow. The round handguards would be replaced with the Knight’s Armament M5 Rail Adapter System. This enabled the M16A4 to do several things. It provided quad Mil-Std-1913 rails. This permitted the attachment of flashlights, lasers, vertical pistol grip as well as night vision to name a few. The infrared laser would become very effective with the use of night vision. The bottom rail could be removed enabling the attachment of an M203 grenade launcher. New grenade launcher sights were designed to attach to the left or right rail to enable the use of optics on the rifle. The detachable carrying handle would go on to be replaced by the Matech back up iron sight which was small and compact. The sight is adjustable for windage and elevation. If the optic was to fail, the rear sight could be engaged and the soldier could shoot with iron sights. Depending on the optic, it may co-witness with the iron sights or it may need to be removed.

Literally there are hundreds of optics that can be mounted on the rifle. The most common is the Trijicon ACOG (Advanced Combat Optical Gunsight) TA31RCO – A4 (NSN: 1240 – 01 – 525 -1648). The A4 on the end indicates bullet drop compensator calibrated for the 20 inch barrel. This is standard issue on the US Marines M16A4 rifles. This is a 4x32mm optic which is powered both by a tritium lamp as well as a fiber optic on top of the scope. Batteries are not required increasing the desirability of this optic. The tritium lamp illuminates the reticle in total darkness while the fiber optic self-adjusts light intensity during daylight according to ambient light conditions. This also allows the shooter to keep both eyes open while engaging targets and maintaining maximum situational awareness. There is a bullet drop compensator built in for the 62gr M855 round. The body of the optic is manufactured from a 7075 T6 aluminum forging, the same as the rifle receivers. The ACOG is attached by a thumbscrew adapter to mount to the Mil-Std-1913 rail. Also available is a killFLASH® Anti-Reflection Devise. This covers the front of the optic to eliminate lens reflection which could reveal one’s location. The ACOG was first used by SOCOM in the SOPMOD Block I Accessory kit. Here the sight gained an excellent reputation for durability and reliability. This optic has been updated and improved over the years resulting in the TA31RCO-A4 and TA31RCO-M4 optics being procured today.

Other popular optics are the M68 Comp2 reflex sight designed by Aimpoint. After 18 months of grueling testing, the Army in 1997 awarded Aimpoint the world’s first military contract for a red dot sight. The current issue is the CompM4 which uses a single AA battery. Aimpoint claims 8 years continuous use from a single AA battery. The intensity of the dot is controlled by a rotary switch on the rear of the optic. There are two models. The early Comp4 has the activation switch and battery compartment on the top right of the optic. The Comp4S (M68CCO) has relocated the switch/battery compartment to the lower right of the optic. The Comp4/4S are night vision (3rd generation) compatible. There are 7 night vision compatible and 9 standard settings of brightness of the dot. The dot is 2-MOA in size. With the standard mounting system, the optic is co-witness with the iron sights. In other words, if the optic was to fail, you may engage your back up sights and you will be able to see the sights through the lens of the optic. To add to the versatility of the Comp4 series, Aimpoint makes a 3x magnifier which mounts behind the sight. The mount allows for pivoting of the magnifier. If you are in a CQB environment you have the 3x magnifier disengaged. Once you need extended range you engage the magnifier and you have a longer range optic.

Another popular accessory is the Specter Gear CST 3-point tactical sling. The sling is 1.25 inches wide and fully ambidextrous. It can be got with a Emergency Release Buckle. This sling does quite a few unique things. The transitional release buckle allows the sling to be quickly extended to allow slack so the rifle can be transitioned from one side to the other. The rifle can be made to hang out of the way from any position of the body and drawn up quickly when needed. Models are also made for the rifle with the M203 as well as the M4 carbine. Another accessory often added is a magazine pouch that sits on the side of the stock. It holds one 30 round magazine. It can be mounted either to the right or the left side, whichever way the sling is installed on the rifle.

In late 2002, after testing, the United States Marine Corps passed over the M4 and M4A1 carbine for the M16A4. According to the Marine Corps this decision was based on reliability. The last week of October, 2002 FNMI received a contract from the Marines for 4,264 M16A4 rifles with a later contract for an additional 27,000 rifles. All Marine Corps M16A4 are equipped with the M5 Rail Adapter System (RAS) for installation of SOPMOD Kit components such as ACOG Reflex Sight as well as the ACOG Day Optical Sight.

As of this writing, both the Army and Marines have procured the M16A4. However, the Army has procured on a very limited basis in favor of the M4 carbine. The Marines continue to procure the M16A4 as its main rifle. This goes back quite some time. During the Army’s XM8 program, the Marines said they would not procure XM8 rifles in favor of the M16A4. They are very pleased with it.

Commercial Versions of the M16A4

Like all military rifles or military equipment for that matter there are always commercial demands. In this case, many companies make a M16A4 rifle in semi-automatic only configuration. But everybody wants the real deal, from the manufacturers who make the rifles for the government. Now they have it with the Colt AR-15A4 and the FN15.

Colt Defense has always been primarily a defense contractor manufacturing weapons for military use. In the 1992-1994 time period, Colt put out its first flat top rifle, the Sporter Competition HBAR Range Selected (R6700CH) which was a 20 inch heavy barrel with no bayonet lug. This was just before the Assault Weapon Ban of 1994. Since then, there were post ban match target series rifle but none of them were of the exact specification of the M16A4. With the sunset of the ban, Colt kept in place the post ban configurations of their commercial rifles due to the fact there were several states which still had bans in effect. Also Colt was doing little in the commercial market due to wartime production of the M4. The Law Enforcement weapons were all of the carbine variations. Colt was producing very little in the area of standard rifles.

In January of 2014 the first commercial M16A4 rifles left Colt, these rifles are called the AR-15A4. This is significant in two ways. First, Colt started using the AR-15 designation on commercial rifles since the late 1980’s. Secondly, they introduced their M16A4 to the commercial market. The decision was greatly based on customer requests. Many Colt customers had returned from Iraq and Afghanistan having used rifles in both the A2 and A4 configuration. So Colt felt it would be important to go back and make an up-to-date commercial rifle configuration that featured a government profile barrel as well as flat top upper receiver.

The Colt AR-15A4 for all intents and purposes is an M16A4 with a semi-automatic only trigger group (semi-auto only lower). It comes with the standard round handguards and detachable carrying handle. Why bare bones? Simply you cannot make everyone happy. Everybody likes their own flavor of stock, rail system, back-up sight, trigger and optic. It is wiser for Colt to provide the basic model and save the customer the money from purchasing additional equipment that the customer will change out anyway. Colt does offer some enhancements over the standard design. The AR-15A4 comes with extended feed ramps. Although not necessary for reliability, it assists in feeding certain types of projectiles without damaging them. Also the rifle comes with an ambidextrous safety and a PMag instead of the aluminum GI magazine. The PMag is a great enhancement in durability and reliability over the aluminum magazine. Also models are offered with Magpul MOE fixed stock, pistol grip, rear sight and handguards in flat dark earth colors. There will be others limited editions offered in various colors. Hopefully one will include a GI model with an M5 RAS and Matech BUIS!

The FN15 Rifle

As previously stated the vast majority of M16A4 rifles were produced by FNMI. Up until January of 2014, FN has never manufactured a semi-auto only rifle of this family of weapons. This leads up to many complicated issues. The TDP does not allow FNMI to use it for any purpose other than making government guns. The FNMI commercial rifles are not made with the government data enabling FNMI to enter the commercial market with the FN15. They offer both a 20 inch barrel rifle and a 16 inch carbine. The FN15 rifles are built in Colombia, SC but on different production lines than their US Government M16A4 rifles and M4 carbines. Recently FNMI was awarded the contract to produce M4 carbines from the US government. Colt Defense had produced as a sole source for the US Government up until this time. After the sole source contract was completed the government put the M4 out for competitive bidding. First the contract was won by Remington. Colt Defense challenged the contract for price issues, it was found the price Remington quoted did not include the royalty Colt gets and the competition was opened up again. When the bidding was done, FNMI took the contract from both
Remington and Colt.

The FN15 rifles marking differ from the military rifle. For instance the FN logo is laser etched on the right side of the magazine well. The barrel has proof marks but uses they stylized FN logo instead of the military marking. The barrel has button cut rifling with a 1 turn in 7 inch twist and is chrome plated bore and chamber. The barrel extension has M4-style feed ramps cut. Significant attention was made to make the rifle look as close as possible to the government rifle. The rifle is marked manufactured by FNH USA out of Fredericksburg, VA.

Like the Colt, the FN15 is bare bones allowing for the customer to customize as per their taste. The rifle comes with the removable carrying handle as well as round handguards. The quality is what one would come to expect from FNMI.

The commercial market demands the same as the military gear. Now one can procure commercial versions of both the M16A4 and M4 carbine by the two most prolific manufacturers for the U.S. government, Colt and FN. All the returning veterans wish to procure the closest to the same weapon they carried in Iraq and Afghanistan from the manufacturers they trusted with their life. The AR15-series rifle is truly the “grown mans erector set”. You take a bare bones rifle and build what your individual flavor is. The M16A4 rifle is not going anywhere, you can expect to see it in all of the US areas of conflict for many years to come. Now Colt and FN are allowing that historical weapon in the commercial market for those who will appreciate the significance of it.

Keltec began development of Carbine Magnum Rimfire 30 at least as far back as 2009. Known as RMR30 during its prototype stage, this 22WMR lightweight semi-auto went into mass production as CMR30 to avoid brand confusion with a Trijicon red dot optic. The carbine was designed as the companion to PMR30 pistol. The two weapons share magazines and have very similar fire control groups. Unlike PMR30, which uses blowback action to cycle low-power ammunition and locked breech for the rest, CMR30 is pure blowback. Since the threaded 16” barrel matches the intended burn rate of the ammunition better than pistol length barrels do, this simplified operation is entirely adequate for liability and negligible felt recoil. Combined with the bore nearly in line with the stock, this low recoil also means negligible muzzle rise and the ability to observe hits through the scope. In a select-fire version made for testing magazines, some rise and drift to the right is detectable, possibly due to the momentum of the empty casings streaming out at about 30 per second. Since the barrel is threaded for standard AR15 muzzle devices, and angled compensator could be of interest to those who want even greater
control in rapid fire.

The carbine is made up mostly of extruded aluminum, with a few laser-cut or machined parts and a molded plastic pistol grip completing it. CMR30 uses a hammer-fired action with a crisp trigger. That, coupled with the well-made barrel, makes it very accurate: 1.5MOA with a variety of loads is pretty respectable for a sub 4-pound autoloader. The full-length monolithic rail has room for a long varmint scope or a shorter optic in tandem with a thermal of night vision device. The Picatinny rail under the forend has room for a bipod, a light/laser and a foregrip. The extending stock is free from wobble, and even though a strong sideways impact would probably damage it, the gun would remain functional. With the stock collapsed, it’s only 22.7” long, short enough to hang under a jacket ready for action. Safety lever, charging handles, and the heel magazine release are ambidextrous. Bolt stop lever is on the left side only.

Maintenance is simple: pull one pin in the back of the receiver and the pistol grip comes off. The bolt, guide rod, and spring come out for cleaning. No further dis-assembly is needed. The gun runs very cleanly: even with a sound suppressor, I only had to pull it apart after over a thousand rounds. The weapon was full of carbon and unburned powder flakes but still ran perfectly.

Having had a pre-production sample of CMR30 since 2010, I’ve been an enthusiastic adopter from the start. The carbine made the most of the marginal cartridge while giving superb ergonomics. In common with FN P90 and HK MP7, CMR30 shoots a lightweight .22 projectile. Unlike 5.7×28 and 4.6×30 cartridges, 22WMR isn’t optimized for penetration of soft armor but excels with controlled expansion bullets. In the 40gr weight recommended for CMR30, most loads are either expanding soft points suitable for small game hunting or FMJ for target practice. FMJ at 1950fps does burn right through 1/4” aluminum diamond plate that showed only a slight divot from 9x19Luger and an even less obvious trace of 22LR bullets. What it lacks in power, this carbine makes up in capacity: 30 shots instead of the usual 10. CMR30 weighs only 3.8 pounds in base configuration with Magpul backup sights, so even the smallest adult or teen defenders can use it to good effect. Combined with the variable length collapsible stock, these features make it a viable personal defense weapon even for people who couldn’t heft a more conventional rifle. We have trained several people with minimal upper body strength and CMR30 really shined in giving them respectable firepower in a light package with simple manual of arms.

While the public release of CMR30 was delayed by concerns about possible federal bans, the design got improved in subtle but important ways. For example, the non-reciprocating charging handles were extended with bolt-on pieces to give them a forward rake so that fingers can’t slip off. The two-piece construction allows the user to shorten one side or the other if desired to reduce snagging. The undersized wire loops intended for sling attachment have been enlarged to accept a wider variety of connectors. But the overall design was sound from the start. It’s quite accurate, and even works well with sound suppressors attached. Used with a Gemtech 22WMR model, it reduced the already moderate blast to almost nothing. Due to supersonic bullets, this caliber is still not fully ear safe even suppressed.

The imperfections of the design are common to CMR30 and PMR30, all stemming from the cartridges and the magazine they use. This double-stack, double-feed polymer magazine is feather-light and inexpensive, but loading it takes some effort. The first 25 rounds are fairly easy, the remainder take some skill to insert without damaging the thin walls of the rimfire cases with the rims of those above them. At this time, no mechanical loader is available. For casual use, I simply load 25 rounds, with the standard 50-round ammunition box filling two. For full capacity, I am eagerly awaiting a solution promised for mid-2016 from Tandemkross which would solve this issue. It would also protect the heel release from accidental activation, something that has occasionally happened when shooting prone and wearing bulky gloves.

While 40-grain ammunition is recommended, the carbine also works with 30-grain and 50-grain loads. The lighter bullets consistently reach 2250fps ranges, with CCI TNT and V-Max exceeding 2300fps. At the time CMR30 came out, that meant 5.7x28mm performance at half the price. Even as the cost of 22WMR ammunition has recently increased, it remains far more available than the more exotic PDW cartridges while offering similar performance. Compared to FN PS90, CMR30 is also 40% lighter. Conventional wisdom is that rimfire cartridges are not reliable enough for defensive use, but I have never actually experience a mis-fire with 22WMR in over 6,000 shots fired over the past five years. The real issues a with 22WMR are the relative fragility in handling and the considerable surface area relative to the recoil thrust available for extraction, the same problem 410 shotshells have. CMR30 has shown consistent reliability of extraction, making it a non-issue. The same narrow case diameter is an advantage for magazine capacity, with 30 rounds fitting in a magazine the size of a 5.7 20-rounder. A centerfire version has been discussed but Keltec is constantly oversold on the rimfire original, so the introduction of new calibers may have to wait.

Most of the accuracy testing I’ve done has been with 3x prismatic scope from Vortex. Since every type of CCI ammunition tried yielded the same 1.5MOA, I strongly suspect the optic or the shooter is the limitation, not the mechanical capability of the carbine. The long optic rail allows high-magnification scope installation, and that’s what I would recommend for varmint control. That, combined with a bottom rail extension to cantilever the bipod closer to the muzzle, would give a steadier shooting platform and improve accuracy to make rodent removal practical out to about 175 yards at which 22WMR goes transonic. Another suggested improvement would be gluing moleskin to the outside of the buttstock struts for a more comfortable cheekweld in cold weather. None of the changes are expensive. The important components – the action, the barrel and the trigger – are all excellent and ready to perform straight out of the box.

CMR30 was eventually released in 2015 and has been extremely popular since. Lighter, less expensive and simpler to operate than its direct competitors, it’s been flying off the shelves at stores. The light weight and compact dimensions come are especially important when traveling by air or by motorcycle. For shooters used to PMR30, the similarity of the manual of arms is yet another bonus. Beyond its obvious utility as a varmint eradicator and a light defensive weapon, CMR30 is just an extremely fun gun to shoot.

J. Curtis Earl is a name well known among most long-time Class III enthusiasts, for those who are not familiar with Mr. Earl there were a series of in-depth articles published in Small Arms Review about the man.

During 1965, Jesse Curtis Earl was one of only three Class III dealers doing business in the United States. Although he operated his business out of Phoenix, Arizona, Mr. Earl became very well known throughout the U.S. (during the pre-internet days) through his magazine advertisements and catalogs. The earliest catalog was published in the early 1970s and cost $1.00. The catalogs were a great source of information on machine guns and machine gun ownership, a subject of which in those days was pretty much unknown. The average citizen, including many firearm enthusiasts of the day, thought machine guns were illegal to possess. The catalogs also had a list of individual state laws and regulations regarding machine gun ownership by individuals. There were photos and a brief description of Earl’s large inventory, he pretty much had in stock any submachine gun, assault rifle, silencer, or belt fed machine gun you could name. In his 1988 catalog he boasted that he had over 850 machine guns in stock. The photos of the collection in his vault were pretty impressive. His specialty was Thompson submachine guns, and in his last catalog he claimed that he had 130 of them in stock. One of his Thompsons, known as the gold embellished “Midas Touch” gun, was featured in the July 1973 issue of Guns and Ammo magazine, providing Curtis with some free publicity. Photos were available for any gun or item listed at $2.00 for a submachine gun and $5.00 for a belt fed weapon. One reoccurring statement in his catalogs was that “all sales are final”.

Curtis had procured some of the guns in his inventory from the Metro-Goldwyn-Mayer (MGM) movie studios auction in 1970. The guns were featured in many movies and TV series and used by a long list of actors including legendary stars like Clark Gable, Humphrey Bogart and James Cagney. Other weapons came from famous American prisons like Attica, Sing-Sing and Alcatraz. The history and use of those guns added a lot of collector appeal. Among the more unique movies guns were two H&R Reising Model 50 submachine guns altered to look like German MP40 maschinenpistols. The altered Reisings were used during a period when real German weapons were unavailable in the U.S. The Reising/MP40s were advertised in Earl’s 1988 catalog for $650.00 each, one of them is on display in the Idaho exhibit. In 1987 Earl sold a large lot of 188 guns to Doug Champlin for display in the Champlin Fighter Museum.

Although he warned potential customers to beware of unscrupulous dealers and false advertising, Mr. Earl became well known for misrepresenting many of the machine guns he offered for sale. Like today, the nature of the Class III business is such that many guns are purchased sight unseen, relying only on the description and photos provided by the seller. One of the more “suspicious” items offered by Earl was a rare “Type 1” slip-on Cutts compensator for the Thompson submachine for $700.00. There has never been any evidence uncovered that such an original factory made compensator ever existed; many believe that he had them locally made.

On the last page of his catalogs Earl included a chart he named “Machineguns Your Best Investment”. On this chart he stated that from 1965 to 1979 the average price of a transferable machine gun increased by 2,080 percent, with an average of 149 percent a year. He predicted that machine gun prices would continue to increase, stating “Buying machine guns could be the best investment you ever made”. He had no idea how accurate his prediction would prove to be. In his 1986 catalog he listed the price of Colt Model 1921 Thompsons “starting at $3500.00”. Keeping in mind Earl’s prices could only be described as “astronomical” the average five-figure selling price of a Colt Thompson today certainly proves his prediction to be accurate. Today’s prices have been largely driven by supply and demand, and the popularity of the internet. Through the internet many individuals have discovered that machine gun ownership was legal in most areas and now provides a primary source to locate them. The catalogs were periodically updated and sold until the 1990s. Reportedly, his catalog sales alone provided a good source of income for Mr. Earl selling up to 3,000 copies a year.

After the laws passed on 19 May 1986, banning the new registration of transferable machine guns, Mr. Earl also predicted that with a finite supply, machine guns would begin to become scarce over time. The choice guns would be sold off and disappear into collections, unlikely to see the light of day until the death of the owner. This prophecy became partly true, at times a particular gun in good condition can be difficult to locate. However, due to the tremendous increase in value, many guns have been offered for sale. When an individual’s transferable Colt M16 was worth $600.00 there was not a lot of incentive to sell it. Now with current M16 prices hovering in the low to mid five-figure area, many individuals with other priorities are cashing out. The good news is that machine guns are coming onto the market; the bad news is they are now far too expensive for many prospective buyer’s budgets.

Despite J. Curtis Earl once being of the best known machine gun dealers in the U.S., opinions of Mr. Earl vary among his numerous customers, few were complimentary. Curtis Earl wanted to leave behind a legacy after his death, so he decided to donate part of his vast collection to a museum. One of the stipulations of his proposed donation was that none of the items in the collection could ever be sold, terms that not many museums seem willing to agree to. For much of his life, Curtis Earl spent his summers in Boise, Idaho, and the winters in Phoenix, Arizona. Prior to his death, Mr. Earl negotiated an agreement to donate a portion of his arms collection to the Idaho State Historical Society, along with a $600,000 endowment for the construction and ongoing care of an exhibit space. His stated intent that his donation of arms and funds be used for public education and enjoyment, he did not want any part of the collection to be sold and disappear from into private collections. J. Curtis Earl passed away on 19 July 2000. After his death, the Idaho State Historical Society dedicated a portion of a building within the Old Idaho Penitentiary complex for the J. Curtis Earl Memorial Arms Exhibit.

The J. Curtis Earl Memorial Exhibit is located in Boise, Idaho at the Old Idaho Penitentiary. The penitentiary itself is a popular local attraction, and quite interesting. Built in 1870, and remaining in operation until 1973, the prison is a sobering reminder that many legendary desperados of the old West often ended up in a small cold cell, or the gallows. There certainly were no amenities afforded prisoners during the days the facility was in operation.

Mr. Earl’s exhibit is inside one of the many buildings on the property, and takes some searching to locate it. The collection includes ancient Luristan bronzes, medieval arms and armor, Revolutionary War firearms and swords, Civil War artifacts, and an 1883 Gatling gun. However, of interest to most SAR readers would be the machine guns. The museum exhibit includes a representative examples of some of the more common weapons fielded by the U.S. and her enemies during World Wars I and II. J. Curtis Earl dedicated the exhibit to “the memory of all those who served and fought, and especially those who paid the supreme sacrifice, in the defense of our great country in order to preserve our freedom and ideals as a free people.”

List of the Thompsons on display

TSMG 1928 Navy 6981
TSMG 1928 Savage S-410430
TSMG 1928 Savage S-250915
TSMG Colt receiver NAC -3
TSMG 1928 Navy 7660
TSMG 1927 3403
TSMG M1 250320
TSMG Colt sn 3000

The J. Curtis Earl Exhibit at the Old Idaho Penitentiary located at 2445 Old Penitentiary Road Boise, Idaho 83712
For more information call (208) 334-2844, or visit their website at http://history.idaho.gov/earl.html
The facility is open daily until 4:30 pm.

The AR-15 rifle was originally conceived by the Armalite Division of the Fairchild Aircraft Corporation by Eugene Stoner, Robert Fremont and James Sullivan. The AR-15 followed an earlier Armalite rifle, the AR-10 chambered for the 7.62×51 cartridge. Both the AR-10 and AR-15 were unique for military rifles of the day, using a lot of aluminum and plastic in their construction. The AR-15 was chambered for a high-velocity .22 caliber round. The AR-15’s space-age appearance, materials, and small caliber made it unappealing to most military establishments, who resisted change. Armalite, discouraged by the lack of sales, decided to sell the rights to the AR-15 design to Colt’s Patent Firearms during 1959. Colt salesman began a worldwide campaign to aggressively market the weapon. In 1961, a substantial number of the AR-15 rifles were requested by U.S. Air Force to replace their aging M1 carbines, but the request was denied. During 1962, a small number of AR-15 rifles were shipped to Vietnam to arm U.S. Special Forces advisors operating there. Reports from the field praised the AR-15’s performance. In 1963 Secretary Robert McNamara ordered M14 production to be terminated and approved an order for a substantial number of AR-15 rifles for the U.S. Army and the Air Force. The AR-15 was adopted as the Rifle, Caliber 5.56mm M16.

The AR-15/M16 rifle was adopted to replace the 7.62 M14 which was proving ill suited for the type of combat then being encountered in Vietnam. The M16 had several advantages over the M14, it was lighter, far more manageable in full-auto operation and the basic ammunition load was nearly double for the same weight. However, the early M16 rifles proved to be quite problematic, the weapon was subject to jamming and malfunctioning during encounters with the enemy, often resulting in the loss of American lives. The problems were found to be a combination of things: lack of proper cleaning, a change in the cartridge propellant, and barrels lacking chromium lining, which were rapidly corroding in the humid climate. Addressing the problems resulted in the adoption of much- improved weapon, the M16A1, in 1967. At the time the problems were occurring it would be very difficult to convince anyone that the M16 would remain in service longer than any other U.S. military rifle, still being issued in 2016 with no viable replacement for the immediate future.

In 1963 Colt introduced a semi-automatic civilian version of the M16 using the rifle’s original name AR-15.

The civilian AR-15 differed slightly from its military counterpart. To satisfy the ATF requirements as to not be “readily converted to full-automatic function”, the hammer, trigger and bolt carrier were designed differently and there was no provision for installing an M16 trip sear. The front pin hole in the early AR-15s lower and upper receivers was larger so that an M16 upper could not be installed. The upper receiver was also designed so that it would interfere with an M16 auto sear in the lower receiver.

Select-fire 5.56mm M16 rifles were also made available for law enforcement sales. Although pistol caliber submachine guns had been deemed largely obsolete for military issue, there was an increasing law enforcement requirement for automatic weapons to match the firepower of a growing number of violent drug dealers. Assault rifles were considered too dangerous for use in a civilian environment, because of a fear of collateral damage by over penetration by their high-velocity rounds. The requirement for a law enforcement submachine gun was being met by purchasing 9mm Israeli UZI s. The UZI was a very reliable weapon, proven in military conflicts, but its big disadvantage was its open-bolt operation, which made precision semiautomatic fire difficult. Heckler and Koch soon entered the law enforcement arena with their excellent MP5 9mm submachine gun that was light, ergonomic, very controllable, and fired from a closed bolt, making it capable of quite accurate semiautomatic fire. The MP5 became very popular with law enforcement agencies around the globe. The MP5 was adopted in the U.S. by a large number of SWAT teams, the FBI, Secret Service, Navy SEALs and the ATF.

Colt, eager to increase law enforcement sales, began to develop a submachine gun to compete with the MP5.

Instead of designing a new weapon, Colt decided to create one using the existing M16 platform. However, Colt wasn’t the first to see the potential of the M16 as a 9mm submachine gun. Back in the 1970s Max Atchisson, a well known inventor and engineer, had an idea for a pistol caliber M16. His conversion of the weapon to 9mm was based on Colt’s compact XM177E1, a short-barrel version of the M16A1 with a telescoping aluminum buttstock. Atchisson assembled three different prototype upper receivers chambered for 9mm Parabellum. Two were open-bolt operated. One with a perforated metal barrel shroud from an M2 aircraft Browning machine gun, one with a standard M16 carbine handguard, and a closed-bolt silenced model using a .45 caliber MAC-10 suppressor converted to a wipeless design. The suppressed 9mm/M16 used a ported barrel to bleed off a calculated amount of gas, reducing the velocity of standard 9mm ammunition to subsonic velocity. Atchison’s 9mm M16 conversions used 9mm magazines originally designed for the Marlin UD-42 and Beretta submachine gun. The idea never progressed past the experimental stage. Atchison’s other M16 projects included a .22 caliber rimfire conversion kit for the M16, which was originally marketed by the Military Armament Corporation. It is unknown if the Colt factory knew of Atchison’s early work, when they embarked on a program to design their 9mm M16 rifle, during the 1980s.

Colt management felt that a 9mm version of the M16 would be attractive to the law enforcement community, who at the time preferred to provide American made weapons, equipment and vehicles to their officers. In addition, many police officers who were military veterans were already well trained in the operation, maintenance, and applying immediate action to clear malfunctions in M16 rifles.

Colt engineer Henry Tatro was assigned the project of designing a 9mm submachine gun out of the 5.56mm M16. The 9x19mm NATO cartridge generates far less chamber pressure than a 5.56mm round thus eliminating the need of the M16’s gas system and rotating bolt. Instead, the 9mm weapon was designed using an unlocked, blowback system. A weight was added to the bolt carrier to keep the bolt closed until the pressure was reduced to a safe level, before the bolt started rearward to first extract and then eject the spent case. The bolt’s rearward motion was slowed by a heavy buffer, before being propelled forward by the recoil spring and a fresh round fed and chambered. The steel weight pinned in the bolt also kept the full-auto cyclic rate to a manageable level. To prevent slam-fires the firing pin is fitted with a spring. Other problems encountered on early models was that the trigger and hammer pins were breaking. To solve the problem Colt began to use hammer and trigger pins made of stainless steel. Another problem was excessive gas coming from the large ejection port, caused by the weapon’s blow-back design. This was especially annoying for left-handed shooters. The problem was addressed by shortening the ejection port by adding a hard polymer gas deflector block at the back of the port opening, and removing a portion of the port cover to accommodate it. The next area that needed to be addressed was the adaptation of a 9mm magazine into the wide M16 magazine well. For this problem magazine well inserts were used. The rear insert housed the ejector, while the feed ramp was on the front insert. The sides of the inserts were drilled to contain small springs to keep the inserts snug in the magazine well. The inserts were secured by three roll pins, two in the front insert and one in the rear one. The original magazines chosen were the proven Israeli double-stack, double-feed design. The magazines were redesigned to hold the bolt rearward when the magazine was emptied. The bolt catch had to be lengthened to prevent breakage when stopping the heavy 9mm bolt. The Colt magazines were produced in 20 and 32 round capacities. Original manufacture magazines can be identified by the Colt logo on the bottom of the floorplate.

Early series production models used the A1 style upper receiver with the integral carry handle, but lacked the forward assist feature. The windage adjustable rear L sight has two leafs: one with the larger aperture is marked 50M for 50 meters, the other leaf has a smaller aperture and is for 50-100 meter ranges. Later models featured a flat-top receiver with a modular rail for mounting modern optics and accessories. A new one-piece magazine adapter is used, but still pinned in place. The lower receivers are roll marked Colt SMG, Cal 9mm NATO followed by the serial number with an HT prefix, reportedly the initials of the lead project engineer Henry Tatro.

Model R0634

The R0634 is similar to the standard Model 635 with a 10.5-inch barrel described below, except it is semiautomatic-only. There is a “filler” pin in the hole normally used for the auto-sear pin on select-fire models. The Model R0634 can be easily converted to select-fire if desired, by installing an auto-sear assembly. The weapon is intended only for law enforcement use.

Model R0635 and R0639

Introduced in 1985, the R0635 is the most common model of the 9mm M16. The standard Model 9mm M16 is fitted with a 10.5-inch long 1/10 twist, chromium-lined barrel. The muzzle end is threaded differently (1/2-36) so that a 5.56 muzzle brake (with a small diameter opening) cannot be accidently installed on it. The weapon can fire semiautomatic or full automatic, the cyclic rate is approximately 800-1000 rounds per minute. The telescoping adjustable buttstock is made from a composite plastic. The R0639 model is similar, except it has a 3-round burst feature.

Model R0635SD

This variation is based on the R0635 model, but features an integral sound suppressor, which is concealed by modified M16A2 handguards. The suppressor was manufactured by Knight’s Armament.

The Colt “Briefcase Gun” or “DOE” Model R0633 and R0633HB

Colt’s Model R0633 9mm M16 submachine gun, better known as the Department of Energy or DOE submachine gun is a rare variation. The DOE prototypes were assembled from standard M16 components, including one with an M16A2 flat-top upper receiver with a removable carry handle and forward assist. The prototype had a rear pop-up sight to align with the folding front sight. The weapon also had shortened carbine round handguards. The 7-inch barrel had an M16 birdcage flash-hider.

Early series production models used the A1 style upper receiver with the integral carry handle. The unique feature of this model is its 7-inch barrel, with a flip-up front sight. The buttstock is the telescoping model used on other Colt submachine guns and carbines. The submachine was designed for concealment or carry in small or confined spaces such as inside a vehicle, where normally a handgun would be carried, but more firepower was required, a submachine gun being far more effective than a handgun in an ambush situation. A number of the “DOE” short barreled upper receivers were available on the market a few years ago, at a premium price. The uppers most likely were taken off of former government weapons that were removed from service and destroyed. Original barreled uppers can be identified by a small proof mark on the upper receiver and the stampings on the barrel. Original Colt barrels generally have the C MP CB (Magnetic Particle inspected – Chrome Bore) markings close to the muzzle, a Colt barrel that was shortened would have them on the section of the barrel that was cut off. The Model R0633HB is the same except it has a hydraulic buffer, which is used to further reduce the full-auto cyclic rate. The “DOE” model is no longer in production.

New Manufacture “DOE” Barrel Assembly

For those who missed out on the opportunity to purchase an original 7-inch “DOE” upper, there is good news.

Very accurate, high quality reproduction assemblies are once again available from Liemohn Manufacturing LLC. The company made an initial run of the replica DOE barrel assemblies, but quickly sold out, and now has decided to start a second run. The 1/10 twist barrel is made of 4140 high quality steel, but is not chrome-lined. The barrels are marked in such a way that they cannot be passed off as originals in the future. Like the originals, Liemohn’s standard muzzles are not threaded, but can be threaded upon request in 1/2×36 or 1/2×28. Other threads are available on special order. The threaded barrel option adds approximately 9/16 of an inch to the barrel length. The handguards are made from a resin cast, and more durable than the rather fragile originals. The front sight components are also made from 4140 steel and are machined in house on a Haas CNC milling machine. The components are gray parkerized, and a very close color match to Colt’s finish. The barrel comes complete with the folding front sight assembly, handguards, barrel nut and delta ring. 9mm upper receivers and other 9mm/M16 parts are also available at extra cost. The 7-inch barrel makes the 9mm/M16 a handy, compact weapon.

NOTE: It is a felony to install a barrel with an overall length less than 16-inches on a stocked semiautomatic AR-15 type rifle without approval from the ATF.

Colt produced an AR-15 semiautomatic-only version of the 9mm carbine with a 16-inch barrel in a number of configurations. Colt still lists an updated 9mm carbine in their 2015 brochure as the model AR6951, this carbine has a flat top upper receiver, flip-up rear sight and a 4-position telescoping buttstock.

Models R0991, R0992, R6951

Colt still offers their 9mm/M16 submachine gun in their military and law enforcement catalogs. The submachine guns have been updated with a third generation composite collapsible buttstock, flat-top receiver, and handguards featuring a modular rail system for mounting a variety of optics and accessories and a 10.5-inch barrel. There are several models available with a choice of semi-automatic only, semi and full automatic or semi and a 3-round burst.

R6951 Safe-Semi, 16.1” Barrel
R0991 Safe-Semi-Auto, 10.5” Barrel
R0992 Safe-Semi-Burst, 10.5” Barrel

Reproduction DOE barrels and 9mm M16 parts.
Liemohn Manufacturing LLC
http://liemohnmfg.com/
machineguntom4@yahoo.com

Publications:

The Black Rifle II by Chris Bartocci
Available from Chipotle Publishing LLC