SecProbe.io

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<TYPE>CORRESP
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<FILENAME>filename1.txt
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UNITED STATES ANTIMONY CORPORATION
47 Cox Gulch     PO Box 643
Thompson Falls, Mt. 59873
Phone: 406-827-3523 Fax: 406-827-3543
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July 19, 2007

VIA EDGAR AND FACSIMILE (202) 942-9648

Ms. April Sifford
Division of Corporation Finance
Securities and Exchange Commission
Mail Stop 7010
100 F Street NE
Washington, D.C. 20549-7010

     Re: United States Antimony Corporation ("USAC")
     Form 10-K for the year ended December 31, 2006 filed on April 4, 2007

Dear Ms. Sifford:

We are responding to the comments of the Staff of the Securities and Exchange
Commission, as set forth in your letter dated July 9, 2007. Subject to the
Staff's review and comment, USAC offers the following responses, and as
appropriate, plans to reflect these in our amended Form 10-KSB for the year
ended December 31, 2006. A draft amendment with marked changes is attached.

SEC COMMENT NO. 1:  ANTIMONY DIVISION, PAGE 5

1. WE NOTE THAT YOU DISCLOSE RESOURCE INFORMATION REPORTED BY A MEXICAN
GOVERNMENT MONOGRAPH THAT DOES NOT APPEAR TO MEET THE CRITERIA OF INDUSTRY GUIDE
7. PLEASE REMOVE THIS INFORMATION.

USAC's response:
----------------

This information has been removed.

SEC COMMENT NO. 2: MANAGEMENT'S DISCUSSION AND ANALYSIS OR PLAN OF OPERATIONS,
PAGE 10; FINANCIAL CONDITION AND LIQUIDITY, PAGE 10

<PAGE>

2. PLEASE EXPAND YOUR DISCUSSION OF FINANCIAL CONDITION AND LIQUIDITY TO
DISCLOSE THAT YOU WERE NOT IN COMPLIANCE WITH THE COVENANTS OF YOUR LONG-TERM
DEBT TO THE EXTENT THAT IT IS REASONABLY POSSIBLE THAT YOU WILL BREACH
RESTRICTIVE COVENANTS, DESCRIBE THE FOLLOWING:

     o    STEPS THAT YOU ARE TAKING TO AVOID THE BREACH;
     o    STEPS THAT YOU INTEND TO TAKE TO CURE, OBTAIN A WAIVER, OR OTHERWISE
          AVOID THE BREACH;
     o    THE IMPACT OR REASONABLY LIKE IMPACT OF THE BREACH ON FINANCIAL
          CONDITION OR OPERATION PERFORMANCE;
     o    ALTERNATE SOURCES OF FUNDING TO PAY ANY RESULTING OBLIGATIONS OR
          REPLACE FUNDING; AND
     o    THE IMPACT OF THE RESTRICTIVE COVENANTS ON YOUR ABILITY TO UNDERTAKE
          ADDITIONAL DEBT OF EQUITY FINANCING.

USAC's response:
----------------

We have added the following to the Financial Condition and Liquidity portion of
the MD&A:

         We are currently not in compliance with certain covenants of our notes
         payable with First State Bank of Thompson Falls (Montana). The total
         balance of these notes at December 31, 2006 was $225,614. These notes
         are personally guaranteed by the Company's president, John C. Lawrence.
         The particular covenants that we have not complied with relate to not
         paying payroll and property taxes when due. During 2006, the Company
         has become current on most of these delinquent taxes. As in past years,
         the Company has obtained a waiver from the bank indicating that they
         will not call the notes due as a result of this non-compliance through
         December 31, 2007. We believe we have the capability to continue making
         the required monthly payments on these notes. We believe that the
         covenants have little impact on the Company's ability to receive
         additional funding which is expected to be raised from sale of shares
         of common stock.

SEC COMMENT NO. 3:  CONSOLIDATED STATEMENTS OF OPERATIONS, PAGE F-3

3. WE NOTE THAT YOU EXCLUDE CORPORATE GENERAL AND ADMINISTRATIVE EXPENSE;
EXPLORATION EXPENSE; GAIN ON SALE OF PROPERTIES, PLANT AND EQUIPMENT AND CHANGES
IN ESTIMATED RECLAMATION COSTS FROM OPERATING INCOME. PLEASE REVISE YOUR
STATEMENTS OF OPERATIONS TO CLASSIFY THESE AMOUNTS IN OPERATIONS, OR TELL US WHY
YOU BELIEVE YOUR CLASSIFICATION IS APPROPRIATE.

USAC's response:
----------------

We agree with your comment and have made the appropriate reclassification of
corporate general and administrative expense; exploration expense; gain on sale
of properties, plant and equipment; and changes in estimated reclamation costs
in the consolidated statements of operations for the years ended December 31,
2006 and 2005.

SEC COMMENT NO. 4:  EXPLORATION AND DEVELOPMENT, PAGE F-9

<PAGE>

4. WE NOTE YOUR POLICY DISCLOSURE RELATED TO EXPLORATION AND DEVELOPMENT COSTS
AS WELL AS YOUR DISCLOSURE RELATING TO YOUR INVESTMENT IN ADM ON PAGE 15. IT
APPEARS THAT YOU HAVE CAPITALIZED DEVELOPMENT COSTS WITHOUT ANY PROVEN OR
PROBABLE RESERVES. PLEASE TELL US THE AMOUNT OF CAPITALIZED DEVELOPMENT COSTS
YOU HAVE RECORDED AS OF DECEMBER 31, 2006 AND 2005, AND EXPLAIN TO US WHY YOU
BELIEVE IT IS APPROPRIATE TO CAPITALIZE THESE COSTS. TELL US MORE SPECIFICALLY
THE NATURE OF THE $106,593 COSTS INCURRED UNDER THE ADM AGREEMENT. IN YOUR
RESPONSE, TELL US WHETHER THESE COSTS INCLUDE THE ANNUAL PAYMENT FOR THE RIGHT
TO EXPLORE AND THE OPTION TO PURCHASE THE PROPERTIES. WE MAY HAVE FURTHER
COMMENT.

USAC's response:
----------------

On December 16, 2005, ADM, a 100% owned subsidiary of USAC, signed a contract
and option agreement that gives ADM the exclusive right to explore and exploit
the San Miguel I and San Miguel II concessions ("the San Miguel project") for
annual payments of $50,000. The agreement also contains an option to purchase
payment of $100,000 annually. In early 2006, our board of directors made a
definitive decision to exercise the purchase option on the San Miguel project.
Our consolidated financial statements state the following in Note 8:

     DURING THE YEAR ENDED DECEMBER 31, 2006, THE COMPANY DECIDED TO PURSUE
     DEVELOPING THE CONCESSIONS. THE PAYMENTS PAID UNDER THIS AGREEMENT IN 2006
     TOTALED $106,593 AND WERE CAPITALIZED AS DEFERRED DEVELOPMENT COSTS IN
     ACCORDANCE WITH THE COMPANY'S ACCOUNTING POLICIES.

This disclosure is an improper characterization of the accounting for these
costs. The payment of $106,593 made in 2006 under the agreement was not
capitalized as development costs, but rather, it was capitalized as mineral
rights in accordance with EITF 04-2 "Whether Mineral Rights Are Tangible or
Intangible Assets"("EITF 04-2"). Mineral rights are defined by EITF 04-2, as
"...the legal right to explore, extract, and retain at least a portion of the
benefits from mineral deposits," and should be capitalized. Paragraph 7 of EITF
04-2 indicates that "Mineral rights include prospecting and exploration permits
if they include an option for the entity to acquire the rights to extract and
retain at least a portion of the benefits from the mineral deposits." Therefore,
we have no capitalized development costs as of December 31, 2006 and 2005.

We have modified the wording in Note 8 changing the reference to deferred
development to mineral rights, created a separate line item for "mineral rights"
in the schedule of property, plant and equipment in Note 6, and added EITF 04-2
as a significant accounting policy in Note 3 in the consolidated financial
statements for the years ended December 31, 2006 and 2005.

SEC COMMENT NO. 5:  ASSET RETIREMENT OBLIGATIONS, PAGE F-10

5. PLEASE PROVIDE THE DISCLOSURES SET FORTH IN PARAGRAPH 22, OF SFAS 143, TO THE
EXTENT APPLICABLE.

USAC's response:
----------------

<PAGE>

On the December 31, 2006 and 2005 balance sheets, USAC had a total of $107,500
and $142,500, respectively, recorded as "Accrued reclamation and closure costs."
Only a minor portion of these costs, $7,500 at both December 31, 2006 and 2005,
is accounted for under SFAS 143. USAC did not include disclosure required by
SFAS 143 because the balances were not considered to be material. The majority
of the accrued reclamation and closure costs at December 31, 2006 and 2005
relates to environmental disturbances dating prior to 2003 and are for a portion
of the antimony operations that is no longer in production. Therefore, the
accrual of these costs falls under Statement of Position 96-1, "Environmental
Remediation Liabilities" and is outside the scope of SFAS 143 which was
effective for periods beginning after June 15, 2002.
We have determined that the term "Accrued reclamation and closure costs" would
be better described as "Accrued reclamation and remediation costs" because the
cost relate to ongoing remediation and not closure of the antimony operation.
Changes in this terminology have been made in the consolidated financial
statements for the years ended December 31, 2006 and 2005.

SEC COMMENT NO. 6: NOTE 12. SECURED CONVERTIBLE AND CONVERTIBLE NOTES PAYABLES,
PAGE F-17, STOCK PURCHASE WARRANTS, PAGE F-18

6. PLEASE DISCLOSE HOW YOU ACCOUNT FOR THE WARRANTS ISSUED IN CONNECTION WITH
THE ISSUANCE OF THE SECURITIES CONVERTIBLE AND CONVERTIBLE NOTES PAYABLES AND
THE AMOUNTS RECORDED IN THE FINANCIAL STATEMENTS RELATED TO THE WARRANTS:

USAC's response:
----------------

As it relates to these warrants, we included the following disclosure in its
Form 10K filing for December 31, 2003:

     "THE COMPANY ACCOUNTED FOR THE DETACHABLE WARRANTS ISSUED IN CONNECTION
     WITH THE NOTES IN ACCORDANCE WITH ACCOUNTING PRINCIPLES BOARD OPINION NO.
     14, AND ESTIMATED A FAIR VALUE OF $0.01 PER WARRANT, OR $30,000,
     ATTRIBUTABLE TO THE DETACHABLE WARRANTS. THE RESULTING VALUE WAS RECORDED
     AS A DEFERRED FINANCING COST AND WILL BE AMORTIZED AS INTEREST EXPENSE OVER
     THE TERMS OF THE RESPECTIVE CONVERTIBLE NOTES PAYABLE. DURING THE YEAR
     ENDED DECEMBER 31, 2003, NONE OF THE DEFERRED OFFERING COSTS HAD YET BEEN
     AMORTIZED TO INTEREST EXPENSE."

The disclosure was updated in 2004 and 2005 and included the amount of offering
costs amortized to interest expense. We removed this disclosure in its 2006
filing because the balance of deferred offering costs at December 31, 2006 was
$3,750 and considered to no longer be material. However, we have added the
disclosure back into the filing in response to your comment.

                                    * * * * *

<PAGE>

In accordance with the Staff's request, we acknowledge that:

     o    The Company is responsible for the adequacy and accuracy of the
          disclosure in its filings with the Commission;

     o    Staff comments or changes to disclosure in response to Staff comments
          do not foreclose the Commission from taking any action with respect to
          the filings; and

     o    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.

We hope that our response adequately addresses the Staff's comments and
respectfully request that the Staff advise us at its earliest convenience if the
Staff believes that any of the responses set forth in this letter are incomplete
or unsatisfactory or if the Staff has any further comments on our filings.

If you have questions on this letter or need further assistance, please do not
hesitate to call John Lawrence at 1-406-827-3523.

Sincerely,

John C. Lawrence
President and Chief Executive Officer

Attachment

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================================================================================

                                  UNITED STATES
                       SECURITIES AND EXCHANGE COMMISSION
                             WASHINGTON, D.C. 20549

                                   FORM 10-KSB

  (Mark One)

     [X]  ANNUAL REPORT UNDER SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT
          OF 1934

                   For the fiscal year ended December 31, 2006

     [ ]  TRANSITION REPORT UNDER SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE
          ACT OF 1934

                 For the transition period ________ to ________

                         Commission file number 33-00215
                       UNITED STATES ANTIMONY CORPORATION
                 (Name of small business issuer in its charter)

             Montana                                           81-0305822
 (State or other jurisdiction of                            (I.R.S. Employer
  incorporation or organization)                           Identification No.)

             P.O. Box 643, Thompson Falls, Montana 59873 (Address of
                     principal executive offices) (Zip code)

       Registrant's telephone number, including area code: (406) 827-3523

Securities registered pursuant to Section 12(b) of the Act: None

Securities registered pursuant to Section 12(g) of the Act: Common Stock, par
value $.01 per share

Check whether the issuer (1) filed all reports required to be filed by Section
13 or 15(d) of the Exchange Act during the past 12 months (or for such shorter
period that the registrant was required to file such reports), and (2) has been
subject to such filing requirements for the past 90 days.
Yes [X] No [ ]

Check if there is no disclosure of delinquent filers in response to Item 405 of
Regulation S-B contained in this form and no disclosure will be contained, to
the best of registrant's knowledge, in definitive proxy or information
statements incorporated by reference in Part III of this Form 10-KSB or any
amendment to this Form 10-KSB. [ ]

Indicate by check mark whether the registrant is a shell company (as defined in
Rule 12b-2 of the Exchange Act Yes [ ] No [X]

The registrant's revenues for its most recent fiscal year were $4,395,368.

The aggregate market value of the voting stock held by non-affiliates of the
registrant, based on the average bid price of such stock, was $16,043,531 as of
March 28, 2006.

At March 28, 2006, the registrant had 39,947,767 outstanding shares of par value
$0.01 common stock.

Transitional Small Business Disclosure Format (Check One):  Yes [ ] No [X]
================================================================================

                                        1
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                                TABLE OF CONTENTS
                                     PART I

ITEM 1.   DESCRIPTION OF BUSINESS.....................................        2
             General .................................................        2
             History..................................................        2
             Overview-2006............................................        2
             Risk Factors.............................................        3
             Antimony Division........................................        4
             Zeolite Division.........................................        5
             Environmental Matters....................................        6
             Employees................................................        8
             Other....................................................        8

ITEM 2.   DESCRIPTION OF PROPERTIES...................................        8
             Antimony Division........................................        8
             Zeolite Division.........................................        8

ITEM 3.   LEGAL PROCEEDINGS...........................................        8

ITEM 4.   SUBMISSION OF MATTERS TO A VOTE OF SECURITY HOLDERS.........        8

                                 PART II

ITEM 5.   MARKET FOR COMMON EQUITY AND RELATED STOCKHOLDER
          MATTERS.....................................................        9

ITEM 6.   MANAGEMENT'S DISCUSSION AND ANALYSIS OR PLAN OF
          OPERATIONS..................................................        9

ITEM 7.   FINANCIAL STATEMENTS........................................       11

ITEM 8.   CHANGES IN AND DISAGREEMENTS WITH ACCOUNTANTS ON
          ACCOUNTING AND FINANCIAL DISCLOSURE.........................       11

ITEM 8-A  CONTROLS AND PROCEDURES.....................................       11

                                PART III

ITEM 9.   DIRECTORS, EXECUTIVE OFFICERS, PROMOTERS AND CONTROL
          PERSONS, COMPLIANCE WITH SECTION 16(a) OF THE EXCHANGE
          ACT.................................................