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UNITED
STATES ANTIMONY CORPORATION

P.O.
Box 643, 47 Cox Gulch Rd

THOMPSON
FALLS, MONTANA 59873-0643

406-827-3523
FAX: 406-827-3543

tfl3543@blackfoot.net E-MAIL

December
5, 2018

Division of Corporation Finance,

Office of Beverages, Apparel and Mining

U.S. Securities & Exchange Commission

100 F Street, NE

Washington, D.C. 20549

Re: United
States Antimony Corporation

Form
10-K for Fiscal Year Ended December 31, 2017

Filed
April 2, 2018

Form
10-Q for the Fiscal Quarter Ended September 30, 2018 Filed November
14, 2018

File
No. 001-08675

Greetings:

This responds to your letter of December 4, 2018, regarding the
Company’s Form 10Q for the fiscal quarter ended September 30,
2018. With respect to the Staff’s comment in the letter, the
Company responds as follows:

Comment:

We note you entered into a Member Interest and Capital Share
Agreement in August 2018 to acquire a subsidiary of the sellers
which includes an antimony plant, equipment and land located in
Reynosa, Mexico and that you accounted for this transaction as an
asset acquisition. In addition to the assets acquired, we note you
also received $1.5 million from the sellers to “assist in the
salvage and transportation costs of the useable equipment”
and that you recognized a $1.5 million gain on plant acquisition
during the third quarter. Please address the following
points:

●

Tell
us the consideration that you transferred as part of this
arrangement and how you determined its cost in accordance with ASC
paragraphs 805-50-30-1 and 30-2.

Management
determined that no consideration was transferred by the Company
under the terms of the Member Interest and Share Capital Purchase
Agreement (“Agreement”). The agreement has a
confidentiality clause that requires approval of the sellers before
public disclosure. We can provide a copy of the agreement
separately upon request. The purchase price of the Member Interest
was a negative $1,500,000 transferred from the seller to the
Company.

The
Agreement provided for no continuing obligation or performance
obligations by the Company to the seller. While the Agreement
contemplated that the funds would be used for salvage and
transportation costs of the useable equipment, there is no
requirement that the funds be used for such. The Company could
leave the equipment in place without violating the terms of the
Agreement.

Management
determined that no liabilities were assumed beyond those known and
were part of the Adjustment Items as provided in the Agreement.
Management assessed the potential environmental and reclamation
requirements but did not identify any through the filing date of
the Form 10Q nor through the date of this letter.

●

Identify
where you recorded the underlying assets that you purchased under
this arrangement and how you determined the amounts
recorded.

Because
no consideration was transferred, management determined that the
purchase price was zero. Thus, no amounts were assigned to the
acquired assets. It is anticipated that refurbishing costs incurred
on these assets will be capitalized.

●

Provide
further details of the terms of the agreement with the sellers
including those related to any obligations you are required to
perform as part of this arrangement and any recourse that the
sellers may have as a result of non-performance.

See
responses above. The Company identified no continuing obligations
as part of the arrangement and there are no provisions for
non-performance in the Agreement.

●

Tell
us how your full recognition of the gain is consistent with your
expectation that you will incur $350,000 to $500,000 to finish
decommissioning of the Reynosa plant as disclosed at page
20.

The
Company is decommissioning the plant and disclosed the estimated
costs as part of the Financial Condition and Liquidity portion of
Management’ Discussion and Analysis. However, there is no
requirement under the Agreement that the plant be decommissioned.
The costs will be expensed or capitalized, as appropriate, when
incurred.

Closing Comments

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

●

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

●

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

●

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.

Sincerely,

/s/ Daniel L Parks

_______________________________________

By: Daniel L Parks

Its: Chief Financial Officer