Comment on FR Doc # 2026-08923

I respectfully submit this comment in support of the Bureau of Alcohol, Tobacco, Firearms, and Explosives’ proposed rule, “Clarifying Special (Occupational) Tax Payments Per Business Activity.” I support the proposed clarification that a person engaged in the business of dealing, importing, or manufacturing firearms regulated under the National Firearms Act should pay one Special Occupational Tax for each taxable business activity conducted at the same location, rather than a separate SOT for each Federal firearms license held at that location when those licenses relate to the same type of business activity. This clarification is sensible, fair, and consistent with the practical reality of how many FFL/SOT businesses operate. A licensee may need multiple FFL license types because the licensing system distinguishes among different categories or subtypes of firearms-related activity. But that does not necessarily mean the licensee is conducting multiple distinct taxable NFA business activities. Where the underlying business activity is the same—such as manufacturing, importing, or dealing—the SOT obligation should be counted by that activity, not by the number of licenses required to carry it out. I also support this rule because it would reduce unnecessary financial burden on affected licensees. The notice explains that some licensees have been paying more SOTs than required, and ATF estimates that clarifying the rule would save affected FFLs approximately $280,240 annually. For small businesses in particular, avoiding duplicate or unnecessary tax payments can matter. These businesses already face substantial compliance responsibilities, recordkeeping obligations, licensing costs, insurance costs, security costs, and ordinary operating expenses. Reducing avoidable costs helps responsible businesses remain viable while continuing to comply with federal law. In my view, the proposed rule promotes clarity and compliance. A rule that is easier to understand is easier to follow. Clarifying that the SOT applies once per taxable NFA business activity at a location—manufacturing, importing, or dealing—will help licensees determine their obligations more accurately and reduce inadvertent overpayment. It should also reduce confusion for both industry members and regulators. I further support the proposal because it does not appear to weaken public safety requirements or remove the need for proper licensing. Licensees would still need the appropriate FFLs for the activities they conduct, and they would still need to pay SOT for each distinct taxable NFA business activity. The rule simply clarifies that multiple licenses connected to the same activity at the same premises should not create duplicative SOT obligations. For these reasons, I respectfully urge ATF to adopt the proposed clarification. It is a reasonable, pro-compliance, pro-small-business change that reduces unnecessary burden while preserving the underlying regulatory framework. Respectfully submitted.