U.S. Customs officials are seeking to impose a civil penalty of almost $4 million on Alexandria arms dealer Samuel Cummings, following an investigation into the marketing here of a popular European handgun by his firm, Interarms, according to Cummings and his attorney.

Cummings, a former Central Intelligence Agency employe who calls himself the "leading {arms} trader in the world," said he received a letter earlier this month saying Customs officials had "reached the conclusion we should pay approximately $4 million" because they believe Interarms mislabeled the origin of imported Walther pistols.

The letter also said Cummings could meet with Customs officials to discuss the matter before the end of January, he said.

Cummings, who said he has been importing the famous Walther pistols for almost 30 years, denied he has misrepresented the origin of the handguns.

The ones he imports are stamped "made in Germany." They were assembled in France, then sent to West Germany for safety testing before shipment to the United States.

U.S. laws require imported goods be labeled with the country of origin.

"Even if {Customs} claim{s} $1, we will categorically disagree," Cummings said, adding that "if I marked {the guns} 'made in France,' I would be in violation of German laws."

Steuart L. Pittman, Cummings attorney, said $4 million represents the value of weapons that Customs has prevented Interarms from importing because of the dispute. This amount represents "the outside penalty" if Customs ultimatly finds there was an attempt to "mislead people on the origin of the weapons," Pittman said.

Pittman said no date has been set for meeting Customs officials in what he characterized as "an administrative step" and "the beginning of a process" typical in disputes between importers and Customs.

He said an alternate option available to Interarms, the exclusive Walther agent in the United States, would be to challenge the Customs findings in federal court.

Customs officials declined to comment yesterday on the dispute with Cummings, saying only that their investigation was not yet concluded. "One can always appeal anything like that," one spokesman said of civil penalties. "These things are always negotiable."

The Walther is prized by gun collectors for its history. Adolf Hitler committed suicide with a Walther, and it was the weapon of choice for fictional secret agent James Bond.

In post-World War II, when West Germany was proscribed from manufacturing arms, the Walther firm arranged for the guns to be made under license by a French company. This relationship has persisted.

A German-made post-World War II Walther pistol costs from $700 to $1,200, while a comparable French-made gun would cost from $400 to $700, according to one local arms dealer.