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Notes -
Just some useful legal context to add to this:
In the 90's the Clinton administration cracked down on so-called "kitchen table" FFLs. A lot of gun enthusiasts became FFLs in the 80's because it allowed them to bypass a lot of the onerous gun control regulations that had been passed in previous decades, at the small small cost of a fee, record keeping requirements, and allowing the ATF to search your home without a warrant or prior notice. But hey at least you can own post-1986 machine guns!
The Clinton administration changed this by requiring that FFLs be "in the business" of manufacturing and/or selling firearms, eliminating the ability of these smaller gun enthusiasts to become FFLs. Even though my state can set clear limits for automobile sales to determine who needs a car dealer license, the ATF seemes unable to set clear limits/amounts for what determines whether or not someone is "in the business" of selling firearms.
They've intentionally left it vague for decades because it creates fear amongst gunowners who never know if the ATF might arbitrarily and capriciously decide to go after them for even a small number of sales. And in cases like OP's story where they seem to be intentionally flirting with that line it gives all the more power and justification to the ATF for overreach.
Source on the Clinton admin FFL changes:
https://www.nraila.org/articles/20220321/democratic-administrations-flip-flop-flip-on-gun-dealer-licensing
Also for your consideration, my state's rules on who needs a car dealership license vs. the ATF's guidance on what counts as being "in the business" of selling firearms:
https://mved.utah.gov/licenses/faq
https://www.regulations.gov/document/ATF-2023-0002-0001
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