Why would Violence Policy Center need a FFL?

Hal

New member
Seems a bit odd that such a hard core anti gun type would have a FFL in DC.
I wonder if he uses it to get around the DC gun laws?


Violence Policy Center
1730 Rhode Island Avenue, NW
Suite 1014
Washington, DC 20036

Phone: (202) 822-8200

Media Inquiries: (202) 822-8200 x104


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You can go here and put in the info and bring it up
https://www.atfonline.gov/fflezcheck/fflSearch.do


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FFLeZCheck 3.1.2


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Federal Firearms License Results



Warning: No one may use this screen, in lieu of the required certified copy of a Federal Firearms License, to acquire a firearm.




License Number:

1-54-XXX-XX-XX-00725


Expiration Date:

03/01/2017


License Name:

SUGARMANN, JOSHUA ALAN


Trade Name:



Premise Address:

1730 RHODE ISLAND AVE NW #1014
WASHINGTON
DC - 20036


Mailing Address:

1730 RHODE ISLAND AVE NW #1014
WASHINGTON
DC - 20036


LOA Issue Date:




LOA Expiration Date:





NOTE: In the event all of the information on the license you are verifying does not match the information displayed above, or if the license has expired, there is a possibility that this may be an attempt at a fraudulent transaction. You should not complete the transaction without first contacting ATF at 1-877-560-2435 for assistance.

The data obtained from this site is not a substitute for a certified copy of the license.

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Hypocrisy maybe?
Or does he know DC is going to become a concealed carry jurisdiction and want's to be ready?
 
I can think of a few.

1. Defense of their property/persons. Hypocritical yes. They don't want YOU to have guns, but every anti-gun celebrity or organization surely has guns or at least armed guards. They may employ and arm guards or have guns on their property.

2. It is likely easier to get guns in DC with an FFL, maybe things that a citizen can't have.

3. Nefarious purposes, manipulating statistics, etc. Perhaps bringing guns into the area, knowing they will end up on the streets, thereby helping their cause of 'guns on the streets increase crime...'

4. Buying guns for destruction? Gun buy-backs?

Can a person/entity could get an FFL if they are not actually doing business?
 
I wrote the following back in 2007 when I became aware of it:

This is the same guy who raised fees on FFL applications and drove home dealers out of business, claiming

The FFL is a public safety scandal created by the very agency charged with enforcing federal firearms laws. By giving a federal gun-dealing license to virtually anyone who can come up with $30 and isn’t a convicted felon, ATF has put criminals in the business of selling guns.

Yet, according to the BATFE database, Sugarmann has held an FFL for at least a dozen years.

It is registered to the same address as his offices at the VPC:

Josh Sugarmann
Violence Policy Center
1730 Rhode Island Avenue, NW
Suite 1014
Washington, DC 20036

Phone: 202 822 8200

FFL: 1-54-000-01-8C-00725

His FFL is patently illegal. First off, it is not a Curio/Relic license. Those have a "03" in the fourth string. The “01" denotes a license for the holder to buy and sell firearms for profit.

Here’s the catch. According to measures Sugarmann proposed, to acquire a Type 1 FFL, the applicant must be in the active business of trading in arms. I wasn’t aware of the VPC selling guns, but that’s exactly what they have to be doing for Sugarmann to hold an FFL.

A dealer is further defined as “a person who devotes time, attention, and labor to dealing in firearms as a regular course of trade or business with the principal objective of livelihood and profit through the repetitive purchase and resale of firearms.” 44 USC § 921(a)(21)(A)

I’d advise everyone reading this to call the VPC offices at the number above and request a transfer. After all, there aren’t many licensed dealers in the District. Otherwise, feel free to call the BATFE D.C. office at (202) 648-8010. I’m currently compiling a FOIA letter requisitioning a copy of his license application and the results of all (if any) BATFE audits of his bound books.

His second sin appears to be tax evasion. The VPC claims 501(c)(3) exemption as a charitable organization, but according to the IRS,

To be tax-exempt under section 501(c)(3) of the Internal Revenue Code, an organization must be organized and operated exclusively for exempt purposes set forth in section 501(c)(3), and none of its earnings may inure to any private shareholder or individual. In addition, it may not be an action organization, i.e., it may not attempt to influence legislation as a substantial part of its activities and it may not participate in any campaign activity for or against political candidates.

…which is exactly what the VPC does. Here’s a handy form (pdf) for reporting Mr. Sugarmann’s perfidity directly.

His third violation is one of zoning. The VPC address (pdf) is zoned “residential/limited non-profit,” with no mention of a retail or business license. If anyone has contact information for the DC zoning board, please let me know.

I got through to the ATF back then, and the agent I spoke with acknowledged that the VPC hadn't been audited since 2002. I have made several FOIA requests, the most recent being last September, but none have been fulfilled.

I'd very much like to see all records of ATF audits, as well as Sugarmann's application.
 
I have made several FOIA requests, the most recent being last September, but none have been fulfilled.
I know piling on is bad form,,,but....maybe if enough requests came in they couldn't be ignored.

If you care to share the process, I'm on board to write a letter or two or three..
 
I suspect all FOI requests, notice of non-profit violations, and any other malfeasance on the part of any anti-gun organizations will fall on the same deaf ears as every other attempt to call this justice department to the mat.

The rampant selective enforcement of law is SOP in this administration. I will refrain from re-listing here the several high profile, unresolved cases in which this has been the case.
 
Here’s the catch. According to measures Sugarmann proposed, to acquire a Type 1 FFL, the applicant must be in the active business of trading in arms.

Ok, here you are speaking about something Sugarmann wants, not what the law actually is, right?

SO, it appears he got his FFL simply to prove his point that he could.

The law says you cannot engage in the business, without getting the license (first).

Does the law say that if you get the license, you must engage in the business? I doubt it.

Getting a license, knowing you don't plan to engage in the business, seems a bit hypocritical to me, but then, that's what these people do best....

As far as the tax status is concerned, that's a can of worms, but if you are a non-profit group, and members of your group (even the head of it) have a license that allows for profit business, AND they don't use it (making no profit), I don't see where the IRS has anything to go on for tax evasion charges. (about that specific item)

I wouldn't call his FFL illegal. Unethical, certainly, but not illegal.

on the other hand, it would make good copy showing how Sen Lee, a big gun control proponent has been arrested on trafficking in illegal weapons, AND Sugarmann, head of the big anti gun group has held a license to deal in weapons for several years. Let people make their own connections...
 
Does the law say that if you get the license, you must engage in the business? I doubt it.

Actually, it does. This is directly from the application:

A license Under 18 U.S.C. Chapter 44:

a. Is NOT a license to carry, use, or possess a firearm.
b. Confers NO right or privilege to conduct business or activity contrary to State or other law.
c. Is a business license, and will NOT be issued to an applicant solely intending to enhance a personal firearms collection. Applicants for a collector of curios and relics license must submit an ATF Form 7CR (5310.16).
d. Is NOT a license to sell ammunition only.
e. Is NOT a license to buy and sell firearms at gun shows only.

As per the quoted statute:

The term "dealer" means (A) any person engaged in the business of selling firearms at wholesale or retail
 
My understanding is that if you get the FFL01 without the intent of actually engaging in business, that's fraud.
 
Getting a license because you believe it is too easy to get the license and you want to make that political point strikes me as political expression.

Fraud implies a different intent than the one that seems most likely.

We should be REALLY careful about restricting political expression, even by our worst enemies.
 
Getting a license because you believe it is too easy to get the license and you want to make that political point strikes me as political expression.

Fraud implies a different intent than the one that seems most likely.

We should be REALLY careful about restricting political expression, even by our worst enemies.
I could see him (Sugarmann) getting a FFL to prove how easy it was - had this been years and years and years ago.

He did go on a witch hunt to shut down the number of FFL holders and published this:
http://www.vpc.org/press/9212mrgd.htm
in 1992.

It would appear he was successful since the number of FFL holders currently is a little over 135,000. In 1992, it was 245,000.

But - - this is 2014 & his FFL is a recent renewal.

Why would he still need a FFL?

BTW - - another rather smelly thing about him and VPC in general is that they have a total revenue of $790,000 and between Sugarmann (the EO) and Rand (the Legislative director) they pull in $245,000 (~ 40%) in salaries.
 
Fraud implies a different intent than the one that seems most likely.
I wouldn't call it fraud, but it shouldn't have been issued and it certainly shouldn't have been renewed. The application for an FFL is here [pdf]. Question 19 asks if the applicant intends to use the license only to acquire personal firearms and instructs the applicant not to submit if the answer is "yes."

There's no provision for "research" or any such thing. It is an application for a license to do business as a dealer. If Sugarmann or his organization are not dealing in firearms, their license was issued under false pretenses.
 
It would appear he was successful since the number of FFL holders currently is a little over 135,000. In 1992, it was 245,000

While he was beating that drum and throwing as much gasoline on that particular fire as he could, Sugarmann alone doesn't get all the credit for the reduction in FFL dealers.

The Clinton administration's increase in the license fee (from $30 to $300 :eek:) played a big part in that, I think.

Sugarmann may have been (almost certainly was) pushing them for that, but he didn't do it all by himself. And the Clinton administration didn't need much of a push....if any.
 
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