What stands out to me in this issue is the DDTC interpretation of "manufacturing" as it applies to gunsmiths, that is inconsistent with decades of alternative interpretation with existing laws. Of course, the DDTC is offering their "opinion" that ultimately may or may not withstand court challenge.
But this is not a prohibition, all this angst is over a 2 grand manufacturing tax here...another damn business expense.
Yeah that's a hefty nut, and yes, it's another governmental agency overreach, (based on what is to my mind a tenuous legal opinion that could be challenged, and should be)... but my GF's annual Starbucks bill is higher than that.
Until then the existing interpretation seems to me to mainly impact occasional FFLs or hobbyists. Any manufacturer or any shop large enough to have prominent visibility in the industry has likely been registered since day one.
For sole proprietors like IT&D it seems to me that this might add $10 to the cost of a typical job...that fee should cover the nut, and it's of lesser impact to the customer than the recent USPS shipping increases.
Loyal customers would likely pay 10x more than that to receive the timely service IT&D offers rather than the 3 year wait and having to play telephone tag with some of the other jokers.
After careful consideration, and with a little creative strategy, I think it's possible for smaller operators to conduct their affairs in a manner that would avoid triggering the registration guidelines as outlined, but if they are not so inclined, just pay the tax and move along and sleep well at night.
All this is easy for me to say, but listen, if this is a real hardship for IT&D, if all the many, many, MANY previous happy customers sent him a 10 spot to keep his services available to the community he'd probably be able to pay the tax for the next decade!
That would be a good use for crowdfunding.
Gunsmith Lives Matter!
