SecProbe.io

November 26 , 2012

Via E-mail
Mr. John C. Lawrence
Chief Executive  Officer
United States Antimony Corporation
P.O. Box 643
Thompson Falls , MT 59873

Re: United States Antimony Corporation
 Form 10-K for Fiscal Year Ended
            December 31 , 2011
Filed March 14 , 2012
File No. 001 -08675

Dear Mr. Lawrence :

We have reviewed your filing an d have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
response.   If yo u do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these  comments, we may have  additional comments.

Form 10 -K for Fiscal Year Ended  December 31, 2011

Item 1. Description of Business

Antimony Division, page 4

1. We note that your share of the domestic antimony market is currently 4% and that
Chinese  producers sup ply 92% of the world’s antimony demand.  Given this, please
provide the  information required by Item 101(h)(4)(iv) of Regulation S -K.
Alternatively, please tell us why  such information would not be material to investors.

Mr. John C. Lawrence
United States Antimony Corporation
November 26, 2012
Page 2

 2. We note your disclosure on pag e 4 and in Note 2 - Concentration of Credit Risk on page
F-6 that during 2011, 72% of sales were made to three customers.   Please revise to
provide disclo sures required by Item 101(h)(iv ) of Regulation S -K related to this
concentration.

Item 2.  Description of Properties

Los Juarez Group, page 12

3. We note you disclose a reserve estimate prepared for your property by the Mexican
Government, this disclosure is not recognized by the SEC, and your company does not
claim any reserves.  The provisions  in Industry Guide 7 preclude the use of any terms
other than proven or probable reserves for disclosure within SEC documents.  Please
modify your disclosure by reclassifying this estimate to mineralized material or another
description as is appropriate.  In this instance, you also need to disclose that such a
deposit would not qualify as a reserve, until a comprehensive evaluation , such as a final
or bankable feasibility study  conclude s legal  and technical viability, and economic
feasibility .

Zeolite Division, page 15

4. We note your description of your zeolite property on this page indicates that the
mine/plant site is located 7 miles west of Preston Idaho, but your map indicates a
location east of Preston Idaho.  Please modify your filing and correct t his discrepancy.

Mine Safety Disclosures, page 21

5. Please provide the disclosure required by Item 104 of Regulation C.  See also the
Instruction to  Item 104 of Regulation C.

6. We note your filing did not include the information regarding your Mine Safety a nd
Health Administration (MSHA) citations received by your U. S. operations, specifically
your Bear River Zeolite Company as required by Section 1503 of the Dodd -Frank Wall
Street Reform and Consumer Protection Act of 2010.  Please modify your filing to
include this required information .

Item 7. Management’s Discussion and Analysis or Plan of Operations , page 24

General

7. Management’s Discussion and Analysis is one of the most critic al aspects of your
disclosure.  As such, we ask that you revise this section to provide an enhanced
executive overview to discuss  the events, trends, and uncertainties that management
views as most critical to the company’s  revenues, financial position, liquidity, plan of

Mr. John C. Lawrence
United States Antimony Corporation
November 26, 2012
Page 3

 operations and results  of operations.  In an effort to assist you in this regard, please refer
to the guidance in SEC Release 33 -8350, available on the  SEC website a t
www.sec.gov./rules/interp/33 -8350.htm .  This guidance is intended to elicit  more
meaningful disclosure in MD&A in a number of areas, including the overall presentation
and focus of MD&A, with general emphasis on the discussion and analysis of known
trends,  demands, commitments, events and uncertainties, and specific guidance on
disclosures about liquidity, capital resources and critical accounting.

8. Please revise to include a critical accounting estimates section to address the existence
of highly material  estimates or assumptions and how these matters may affect the
financial statements.   Your revised disclosure should supplement, not duplicate, the
description of accounting policies that are already disclose d in the notes to the financial
statements. Your  disclosure should discuss the judgments and uncertainties that affect
the application of your critical accounting policies and the likelihood that materially
different amounts could be reported under different conditions or using different
assumptions.   Please refer to the Commission’s guidance concerning Critical
Accounting Estimates and revise Management’s Discussion and Analysis to comply
with the requ ired disclosures as necessary.  The guidance is available on the SEC
website a t www.sec.gov./rules/interp/33 -8350.htm .  Please note that your response letter
dated October 13, 2010 indicated that you will include such disclosures in future filings.

Results of Operations, page 25

9. Please revise t o expand your disclosures for each period presented to provide a detailed
analysis of the material components of your consolidated statements of operations. The
discussions should describe and quantify underlying material activities that generate
variances  between periods (e.g.  provide a narrative discussion of the extent to which
increases in net sales or revenues are attributable to increases in prices or to increases in
the volume or amount of goods or services being sold).   Please ensure to quantify the
effect of each causal factor that you cite for material changes in your financial
statements.   Your revised variance analysis should fully explain the changes between
periods.   Refer to Item 303 of Regulation S -K and SEC Release No. 33 -8350.

Financial Condition and Liquidity, page 26

10. Please revise your disclosures here to include an analysis of the components of the
statements of cash flows (i.e. operating, investing, and financing activities) that explains
the significant year -to-year variations in th e line items (e.g. explain the significant
change in accounts receivable, inventories etc.,).   Your analysis of cash flows should not
merely recite information presented in the consolidated statement of cash flows.   Please
refer  to the SEC’s Interpretation : Commission Guidance Regarding Management's
Discussion and Analysis of Financial Condition and Results of Operations [Release No.
33-8350,  <http://www.sec.gov/rules/interp/33 -8350.htm >] as it rel ates to liquidity and
capital resources.

Mr. John C. Lawrence
United States Antimony Corporation
November 26, 2012
Page 4

11. Please revise to include detailed discussions of your liquidity and capital resources  to
identify the trends, demands, commitments, events and uncertainties as required by  Item
303(a)(1) and (2) of Regulation S -K.

12. We note the various financial commitments mentioned in your financial statements
including the current portion of various notes payable and the cumulative dividends in
arrears on your Series B and Series D preferred stock.   Please quantify your variou s
commitments for the upcoming year, and provide a discussion of the sources of capital
which will be used to service your financial commitments.  In particular, please address
whether the failure to pay preferred dividends will have any effect on your abi lity to
raise funds in the future.  See Item 303(a)(2)(i) of Regulation S -K.

Item 9A. Controls and Procedures , page 27

Changes in Internal Control Over Financial Reporting, page 28

13. Please revise to specifically disclose any change in your internal con trol over financial
reporting that occurred during your last fiscal quarter that has materially affected, or is
reasonably likely to materially affect, your internal control over financial
reporting.   Refer to Item 308(c) of Regulation S -K.  We also note t he lack of similar
disclosures in your Forms 10 -Q for the quarters ended March 31, 2012, June 30, 2012
and September 30, 2012.    Please note that these disclosures should also specifically
clarify the control changes made to address your material weaknesse s.  Please revise.

Financial Statements

Notes to Financial Statements

2. Concentration of Risk, page F -6

14. We note your disclosure of concentration of sales. To enhance investor’s understanding
of your business, please revise to disclose the concentrati on of accounts receivable and
provide disclosures required by FASB ASC 275 -10-50-16.

3. Summary of significant accounting policies , page F -6

Revenue Recognition, page F -9

15. We note your disclosure that revenue from exclusive sales agreements with multipl e
elements is recognized pro -rata over the duration of each element within the
contracts.   Tell us and revise to disclose how your revenue recognition policy relating to
sales agreements with multiple elements complies with FASB ASC 605 -25 and provide
the disclosures required by FASB ASC 605 -25-50-2.

Mr. John C. Lawrence
United States Antimony Corporation
November 26, 2012
Page 5

 Exhibits

16. We note that the certifications filed as Exhibits 31.1, 31.2, 32.1 and 32.2 with your
Form 10 -K and Form 10 -Q for the fiscal quarters ended June 30, 2012, and September
30, 2012 have not been signed and/or dated.  Please refile these certifications as signed
by the necessary executive officers.

Signatures

17. Please revise to include the signature of your P rincipal Accounting Officer  or Controller .
See General Instruction D(2) of Form 10 -K.

Form s 10-Q for the Quarterly Period s Ended June 30, 2012, and September 30, 2012

18. We note that your Forms 10 -Q for the se periods plus the  quarterly p eriod ended March
31, 2012  are not properly signed and dated by your principal  executive and principal
financial officers.  Please amend your Forms 10 -Q to provide the
appropriate signatures.

Item 2. Management’s Discussion and Analysis or Plan of Operat ions, page 13

19. We note you disclose the non -GAAP measures of EBITDA and EBITDA/ lb. Metal.   It
appears your calculation of EBITDA (i.e. excluding general and administrative costs,
professional fees, etc.) is not consistent with that as defined in Item 10(e)  of Regulation
S-K.  As such, revise to remove such measure or rename it (e.g. Adjusted EBITDA) and
provide the disclosures required by 10(e)(i) of Regulation S -K.  Also refer to Questions
103.01 and 103.02 of the Division’s Compliance and Disclosure Inter pretation on Non -
GAAP Financial Measures.

Other Exchange Reports

20. Please revise your Exchange Act reports as necessary, to comply with the comments
above.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the compa ny and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comments, please provide  a written statement from the co mpany
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

Mr. John C. Lawrence
United States Antimony Corporation
November 26, 2012
Page 6

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

You may contact Raj Rajan  at 202 -551-3388 or B rian K. Bhandari at 202 -551-3390  if
you have questions regarding comments on the financial statements and relate d matters.  If you
have questions concerning the Engineering comments contact George K. Schuler, Mining
Engineer at 202 -551-3718 .  Please contact Adam Turk at 20 2-551-3657 or Pamela Howell  at
202-551-3357  with any other questions.

 Sincerely,

 /s/Tia L. Jenkins

Tia L. Jenkins
Senior Assistant Chief Accountant
Office of Beverages, Apparel , and
Mining