Just filled out my renewal form. It asks (Section C, Item 7a & b): How many firearms have you bought or acquired with your firearms license over the past 3 years? How many firearms have you sold or disposed of with your firearms license over the past 3 years?
My guess is if you write 20 and 19 in these boxes, you will be one of the few C&R holders who is visited by a BATFE inspector. He will not be cheerful, open-minded, while making a random, courtesy visit. He will be investigating your apparent abuse of a C&R license. The people you transferred the 19 rifles to will be questioned to verify your statements. If 19 people say you sold them a rifle and made money on the deal you are sunk. Lying to a federal agent is very, very bad.
My guess is if you write 20 and 19 in these boxes, you will be one of the few C&R holders who is visited by a BATFE inspector. He will not be cheerful, open-minded, while making a random, courtesy visit. He will be investigating your apparent abuse of a C&R license. The people you transferred the 19 rifles to will be questioned to verify your statements. If 19 people say you sold them a rifle and made money on the deal you are sunk. Lying to a federal agent is very, very bad.