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Originally Posted by PayneTrain
it is a bunch of COTS parts that have been bolted on to some Lexan.
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This would make these parts no longer COTS
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Q. If a COTS item is mounted to an assembly of fabricated components, is the item still considered COTS if it is otherwise unmodified? (ie, no mounting holes drilled in it)
A. No. Mounting a COTS item into an assembly is considered modifying it, making it a Fabricated Item. If the COTS item was removed from the larger assembly and otherwise unmodified, it would be considered a COTS item.
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emphasis mine
So if you have not included the weight of these items in your withholding allowance then it may have been illegal.