AM15 .22LR Upper, 275 Round Magazine, for M11/9 SMG

Tactical Innovations will soon be selling a .22 LR upper receiver for the M11/9 submachine gun (semi-auto clones are not compatible). The receiver uses American 180 .22 drum magazines which can hold up to 275 rounds.

The AM15 Upper Receiver system, along with quad rail, a 165 rd drum and winder will cost $1395 plus shipping. They will be shipping it as soon as they get ATF approval.

The below youtube video from 2007, posted by a company called Thompson Machine, shows an upper receiver for the M11/9 that uses the American 180 .22 drums …

[ Many thanks to Jeff for emailing me the link. ]

Steve Johnson

Founder and Dictator-In-Chief of TFB. A passionate gun owner, a shooting enthusiast and totally tacti-uncool. Favorite first date location: any gun range. Steve can be contacted here.


  • Raoul O’Shaugnessy

    I dont get it. If the upper isnt the controlled part, what’s ATFE’s authority over it? Wouldnt the upper be no different, legally, than, say, a scope or muzzle break in that it is unregulated and thus out of ATFE’s jurisdiction?

    • Raoul, good point. Often gun companies will send a letter to the ATF to get accessories approved. This way they protect themselves if someone at the ATF takes a dislike to them or changes the rules.

  • zincorium


    Out of curiosity, is there any situation this would be a practical weapon? I know the original 180 was tried out as a prison guard’s weapon, as it was thought to not be capable of penetrating armor (later found to be dangerously false).

    At this point, I guess it could be crowned ‘king of the bullet hoses’.

  • Cymond

    Heh, yeah, right. You may note that Thompson Machine never actually produced & sold any of those uppers. I read somewhere that ATF never approved the design. Several companies have tried making beltfed uppers for the MAC series but ATF tends to classify them as post-86 machineguns. Also look at the XMG-8 – it was an MG34-based (German beltfed 8mm LMG/GPMG) AR-15 upper. First ATF ruled that it was a Title-1 firearm, not just an upper. ATF later ruled that using it on a registered fullauto lower converted the XMG-8 to a post-86 MG.

    I doubt this product will ever come to market. Believe me, I would love to get my hands on one. M10s & M11/9s are the cheapest way to get into fullautos, and there are several uppers on the market that make them into fairly decent guns.

    • Cymond, thanks for the info.

  • Alaskan

    It’s missing something from a AK variant..
    Talk about your “kitchen sink” gun..

  • Clodboy

    “So this AR-15, a Mac-11, a 10-22 and a Degtyarov DP-28 walk into a teleporter booth…”

  • Aurelien

    Is that some kind of modern-day take on the Lewis Machine-gun ?

  • dogon1013

    The m11/9 is an open bolt gun. And if you make an upper for it that also holds the magazine, like this one does, then the upper itself might be able to fire without the serialized lower attatched(just pull the bolt back and release). This is bad as you have now created a machinegun…..that is why ATF aproval is usually gotten, to prove that the upper alone is not a firearm by itself.

  • Jim

    Are they joking about the price here? Someone should remake this once more, but fit it on a AR-15 receiver, produce the upper for under 700 bucks, and make the barrel long enough that it doesn’t require a tax stamp.

  • spudfiles

    “Out of curiosity, is there any situation this would be a practical weapon?”

    Apparently the similar MGV-176 was used in the conflict in Bosnia:

    An American 180 was also adequate for this engagement:

    While the performance of the rimfire round is marginal, in close quarter or urban combat situations I’m sure the high volume of fire would more than compensate for the relatively low muzzle energy. The concept is not new either – William DeLisle, designer of the notorious suppressed carbine that bears his name, proposed a 22LR machinegun for jungle warfare back in 1943: (last paragraph of page 31)

  • Cymond

    Jim, Tactical Innovations already has a version for full-auto AR-15/M-16s, but it is also incompatible with semi-autos. They originally talked about making a semi-only version, but the website doesn’t mention that anymore. I guess there’s some legal reason that it can’t be used on a semi-auto, or maybe the problem is some mechanical quirk. Anyway, since it is for fullauto only, it can have a short barrel without a tax stamp.

    zincoriumon, I doubt it is very practical for any real situation (throw the switch to semi and it would rock for zombies). The main appeal is that M10s and M11/9s are the cheapest fullauto guns that we can buy. A M11/9 is about $4000 while a fullauto AR-15 is about $10,000. This turns an uncontrollable sheet metal bullet hose into something that is fun and affordable to shoot.

  • dogon1013


    an M11/9 can be had for $2.5K-$3K these days (probably due to the slow eceonomy)….If you search for a bargain.

  • mmathers

    This is an awesome counterpart to Lakeside Machine’s beltfed 22LR AR15 upper. Something that uses an AM180 drum is totally awesome.


  • mmathers

    One last comment vs. the LM beltfed AR upper. Belts are a pain to reload. I don’t have experience loading the AM180 drums but with the loading tray, it looks a might bit easier than “open the pocket, twist the round in, repeat” or using LM’s “quick-loader” in sets of 10.

  • Looks like fun… but its got Ugly Gun Sunday written all over it. What a mongrel.

  • jo

    I believe that either Tactical Innovations or Thompson Machine tried doing select fire, but semi auto mode kept having malfunctions. Therefore full auto only.

  • Matt

    That thing sure isn’t pretty. But you know what? When you’re having a lot of fun, who needs pretty?

    Here’s my take. When I hold down the trigger on a typical mag for an M11, I get, I believe it to be 32 rounds of full-auto 9mm burst. That goes by FAST! About 2 seconds worth of full-auto. So increasing that time to about 5 times as much or more, could be one heck of a good time. Just don’t tell me until you are done loading the magazine, please!