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Dear ATF Technical Department:
I am writing in regards to a Lahti L39 rifle that has been converted to a 50 caliber bolt action rifle. I
hope you will be kind enough to help me.
This rifle was imported before the old ban on rifles of greater than 50 caliber, and it was also
converted from 20mm to 50 caliber before the time at which it would have had to be registered.
I was fortunate enough to speak with ATF Agent Mike Cooney at 404-417-2750 on November 17,
2008, and our phone call ended about 2:48 PM CST. After I described the rifle and its history to
Agent Cooney, he very kindly told me that it is the same as any other 50 caliber non-NFA gun
and that in its present configuration, it is not subject to taxing or registration through the ATF.
I wrote up a document attesting to these facts, so that there would not be any misunderstandings
should someone in a position of authority see the rifle and become curious as to its legal
I also realize that sometimes another person cannot always be relied upon to understand the
legal standing of a rifle, and may choose not to rely on my document. I wish to avoid any
appearance of misdoing or impropriety.
Therefore, I am kindly asking you to send me an official letter confirming in writing that this rifle is,
like any other 50 caliber single shot rifle, not subject to taxation or registration and that it may be
posessed by anyone not otherwise prohibited from posession of a 50 caliber rifle.
I would like to present some facts about the rifle that show that it can fire only the 50 caliber
ammunition and cannot be used in any way with the original 20mm ammunition and I hope these
will be useful to you in helping me.
In the current configuration, it is a single shot 50 caliber bolt action rifle.
The breech and barrel cannot accept an round larger than a 50 BMG. It is physically impossible
to load a 20mm round because the barrel and chamber cannot accept the 20mm round’s
diameter or its length.
I have taken some pictures for you, to show that the rifle is a 50 caliber rifle.
Figure 1 – breech measurement.
Figure 2 – close-up of the measurement.
Figure 3 – shows a 50 caliber BMG round inserted.
Figure 4 – close up of figure 3.
Figure 5 – the muzzle brake’s inside diameter.
Figure 6- close up of figure 5.
Figure 7 – the barrel’s bore size measured at 0.5 inch.
Figure 8 – close up of figure 7.
Figures 9 and 10 – views of the rifle itself.
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Figure 1.) Breech end of 50 caliber barrel.
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Figure 2.) Scale showing that the barrel can only accept the diameter of 50 caliber BMG
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Figure 3.) a 50 caliber BMG round inserted into the breech of the barrel.
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Figure 4.) A close-up view of a 50 caliber BMG round in the rifle.
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Figure 5.) the end of the muzzle brake.
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Figure 6.) The close view of the end of the muzzle brake. The muzzle brake’s bore is
approximately 0.59 inches in diameter, but this is not so important, as the barrel is the key factor.
It is mentioned only to show that it is not a 20mm part (which would be 25/32 on this scale).
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Figure 7.) The muzzle brake has been removed so that the barrel bore may be measured and
shown to be 0.5 inch diameter.
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Figure 8.) The bore measures 0.5 inch as far as it is possible for me to check it.
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Figure 9.) the rifle
Figure 10.) the rifle
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To whom it may concern,
I, NAME, attest that I am the creator of this letter and that to the best of my knowledge, everything
herein is factual and accurate.
Signature: _______________________________________________
On this the ________ day of __________________ in the year ___________,
Before me the undersigned, personally appeared NAME, personally known to me or proved to me
on the basis of satisfactory evidence to be the persone whose name is subscribed to in this
instrument, and acknowleged that he executed it.
Notary Signature: _______________________________
Notary Name:__________________________________
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