Look like that FFL hasn't done much for your knowledge in this area.
I'm not going to play word games with you. As I told you, I've held a Class 1 FFL for over 15 years. And in that time I've personally
dealt with the ATF many times regarding paperwork, along with what you can and cannot do. Especially in regards to buying, selling and transferring firearms.
I will tell you this much. What you're doing, or thinking you can do is foolish. You are treading in a very grey area with a 3 letter government agency.
Another thing I have found in dealing with these people for over a period of a decade and a half, is they are very politically motivated. Their posture is ever changing depending on the political climate they're working in, or under. Today, under an extremely liberal, anti gun Presidential Administration, they are far more likely to respond in a negative way, to matters that might have gotten by with a "raised eyebrow" under the more gun friendly administrations of the past. I know this for a fact, because I have had several agents tell me that all but word for word. The IRS is no different. Look how they have gone after people with opposing political views in the last few years. All of them were every bit as "right" as you, if not more so. It didn't get them very far, did it?
ATF agents are no different than anyone else. If you treat them cordially, and with utmost respect, they will respond accordingly..... Most of the time. But if you act cocky, and try giving them a lot of slick talk in an attempt to act like you know more than they do, you're headed down a dead end road fast.
Again like the IRS, and most all other 3 letter government agencies, these people quite literally have the power of God, and can destroy your life with a single stroke of a pen. And if they're wrong, they'll walk away without so much as a, "we're sorry". And they don't have to be right, in order for you to be wrong.
You're playing with fire. And there is zero reward even if you don't get burned. I'm sorry, but you're pushing a bad position. To me that pretty much defines stupidity, because much like Russian Roulette, it's all risk and no reward.