Get to Sniper School!
 

Here is a trick to get 36 hits. Its not a hack or cheat, but a slight slip in the game. While taking your rifle test only bring up your sights right before you fire. Place your green dot or cross hairs over the target when it pops up, then zoom in on your sights and fire quickly then zoom back out. If you keep doing this it doesnt give his breathing a chance to kick in and start moving your sights around. .... Have Fun.. PaleHorse

This doesnt work all the time though.