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RESP823

September 25, 2006

Via EDGAR

Securities and Exchange Commission

ATTN:  April Sifford and Gary Newberry

Division of Corporation Finance

100 F Street, NE

Washington, DC  20549-7010

Re:                     Comment letter dated August 23, 2006

                           Solitario Resources Corporation ("Solitario or the "Company")

                           Form 10-K for the Year Ended December 31, 2005

                           Filed on March 28, 2006

                           SEC File No. 0-50602

Dear Ms. Sifford and Mr. Newberry:

          Set forth below are our responses to the comments of the staff of the Securities and Exchange Commission (the "Staff").  The number of the responses and headings set forth below correspond to the numbered comments and headings on the letter from the Staff.

Furthermore, Solitario acknowledges the following:

          Solitario is responsible for the adequacy and accuracy of the disclosure in our filings with the Securities and Exchange Commission (the "SEC"); and

          Staff comments or changes to disclosures in response to Staff comments do not foreclose the SEC from taking any action with respect to our filings; and

          Solitario may not assert Staff comments as a defense in any proceeding initiated by the SEC or any person under the federal securities laws of the United States

Form 10-K For the Fiscal Year ended December 31, 2005

Consolidated Statements of Operations

1.          We have considered your response to our prior comment number four in our letter of July 14, 2006	.  We do not agree with your conclusions.  We note that Statement of Financial Accounting Standards (SFAS) 7, paragraph 9, indicates that exploring for and developing natural resources, or acquiring mineral rights, is typically a development stage enterprise.  Further, the sale of a property would not be considered revenue, as defined in Regulation S-X 5-03(b), but appears to be more appropriately classified as a gain on discontinued operation under the provisions of SFAS 144.

The staff does not believe the phrase "new business" as used in the context of your response is a controlling factor in applying the requirements of SFAS 7.  Your disclosures in Note 1 indicate you had no activity prior to 1993, the year you became a public company, and this would be the relevant date for determining whether you are establishing a new business.  In addition, SFAS 7, paragraph 4, indicates that it applies to any separate financial statements of a development stage subsidiary of an established enterprise.

As such your operations appear to meet the criteria of SFAS 7 paragraph 8(b).  We reissue our prior comment four in our letter dated July 14, 2006.

RESPONSE:

We believe our presentation as an established business is correct.  As a minerals exploration company our fundamental and historically sole business is the acquisition of mineral properties for sale or joint venture.  This has been consistently disclosed in our financial statements.  It is essential to an understanding of our financial statements that our business is selling and joint venturing properties.  Although there is the possibility, in the future, that we may develop and mine a property we hold, that is not our primary focus and we have never done that in our history.  We do not now and we have never had mining engineers or metallurgists or mine operating staff.  Our only technical employees during our 13-year operating history (and currently) have been geologists.

"The sale of property would not be considered revenue, as defined in Regulation S-X 5-03(b), but appears more appropriately classified as a gain on discontinued operations under the provisions of SFAS 144"

We respectfully disagree for the following reasons:

As discussed in more detail below we sold our Yanacocha property in April of 2000 for $6,000,000 and reported the net proceeds from this sale as revenue.  In addition we have reported significant revenues, both on an annual and quarterly basis, from joint venture proceeds in excess of our capitalized costs.

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We believe reporting the proceeds from the Yanacocha sale as a gain on discontinued operations would be inconsistent with the facts and circumstances of that sale, the history of the project and our business.  For example, we have never acquired a property with our primary intention to develop and mine the property.  We have never conducted development or mining operations at Yanacocha or any other property.

It is important to note that the Yanacocha property never had any separate operations, or revenue generation from production.  Changing the disclosure to reflect this one transaction as though it was discontinued operations (such as mining or development) would be inconsistent with our activities on the Yanacocha property, or any other property in our 13-year history.   Our exploration activities on our Yanacocha property were only intended to prepare it for sale or joint venture.  This is consistent with our treatment on all of our acquisitions of 36 separate mineral interest properties in our 13-year history, 12 of which we still own, including our Bongará project in Peru, which was acquired in 1993 as one of our first properties.

We believe the provisions of SFAS 144 do not apply to the Yanacocha sale because the transaction took place in April of 2000 and SFAS 144 was not effective for Solitario until January 1, 2002.  However, we have reviewed SFAS 144 for supplemental guidance, with respect to discontinued operations and believe the sale of Yanacocha would not qualify as discontinued operations.  The reason we believe such is that our operations to perform exploration activities to enhance our properties for sale or joint venture did not change prior to, during and subsequent to the sale of Yanacocha.  We believe the sale of our Yanacocha property was in the ordinary course of our business.

As part of our review of Generally Accepted Accounting Principles, we reviewed the following accounting guidance, which was in effect at the time of the Yanacocha sale in April 2000:

1.          SFAS 121 "Accounting for the Impairment of Long-Lived Assets and for Long-Lived Assets to be Disposed Of"; and

2.          APB 30 "Reporting the Results of Operations - Reporting the effects of a Disposal of a Segment of a Business, and Extraordinary, Unusual and Infrequently Occurring Events and Transactions,"

Based upon that review, we respectfully submit that the sale of our Yanacocha property was not a disposal of a discontinued operation but in the ordinary course of our business, as we performed the same operations and procedures before, during and after the sale of Yanacocha, namely:

a). Acquiring properties for sale or joint venture, and

b). performing exploration activities on those properties to enhance the salability or joint venture potential of the properties.

We believe that this conclusion is supported by the following facts: That no employees were terminated or reassigned as a result of the sale of the Yanacocha property; no employees were conducting any significant exploration activities on Yanacocha prior to the sale; the only visits we had to the property during the two-year period prior to the sale were for limited geologic studies to enhance the property for sale or joint venture activities.  Typically the sale of mineral properties is infrequent, however it is not an unusual item and it is something that Solitario is in the business of doing.  Therefore, in accordance with paragraph 26 of APB 30, we properly disclosed the sale of our Yanacocha property as a separate component of income from continuing operations, as this was an infrequent transaction.

The recognition of revenue is a basic requirement of financial statement presentation.  We have reviewed Rule 5-03 (b) 1 (a)-(e) of Regulation S-X which states:

 "Net Sales and Gross Revenues.  State separately: (a) net sales of tangible products (gross sales less discounts and allowances): (b) operating revenues of public utilities or others; (c) income from rentals; (d) revenues from services; and (e) other revenues."

We believe that the recognition of revenues on the sale of our Yanacocha property is in accordance with Rule 5-03 (b) 1 (a)-(e).  The sale of our mineral property is the sale of a tangible asset, which we were holding for sale or joint venture.  This position is further supported by Accounting Research Bulletin 43, chapter 1A, paragraph 1 and APB 10, "Omnibus Opinion 1966," paragraph 12 which states:

"Profit is deemed to be realized when a sale in the ordinary course of business is effected, unless the circumstances are such that the collection of the sale price is not reasonably assured.  The Board reaffirms this statement; it believes that revenues should ordinarily be accounted for at the time the transaction is completed, with appropriate provision for uncollectible accounts."

We respectfully submit that our recognition of revenues on the sale of the Yanacocha property was also consistent with the opening paragraphs of the SEC Staff Accounting Bulletin No. 101 which states:

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1.          Revenue recognition - general

The accounting literature on revenue recognition includes both broad conceptual discussions as well a certain industry-specific guidance.  If a transaction is within the scope of specific authoritative literature that provides revenue recognition guidance, that literature should be applied.  However in the absence of authoritative literature addressing a specific arrangement or a specific industry, the staff will consider the existing authoritative accounting standards as well as the broad revenue recognition criteria specified in the FASB's conceptual framework that contain basic guidelines for revenue recognition.

Based on these guidelines, revenue should not be recognized until it is realized or realizable and earned.  Concepts Statement 5, paragraph 83(b) states that "an entity's revenue-earning activities involve delivering or producing goods, rendering services, or other activities that constitute its ongoing major central operations, and revenues are considered to have been earned when the entity has substantially accomplished what it must due to be entitled to the benefits represented by the revenues."  Paragraph 84(a) continues "the two conditions (being realized or realizable and being earned) are usually met by the time the product or merchandise is delivered or services are rendered to customers, and revenues from manufacturing and selling activities and gains and losses from the sale of other assets are commonly recognized at the time of sale (usually meaning delivery)."   Paragraph 84(d) states that "If services are rendered or rights to use assets extend continuously over time (for example, interest or rent), reliable measures based on contractual prices established in advance are commonly available, and revenues may be recognized as time passes.

The staff believes that revenue is generally realized or realizable and earned when all of the following criteria are met:

          Persuasive evidence of an arrangement exists

          Delivery has occurred or services have been rendered

          The seller's price to the buyer is fixed or determinable, and

          Collectibility is reasonably assured.

All of the above criteria were met with regard to the sale of our Yanacocha property and accordingly we believe the sale was in the ordinary course of our business and we properly recorded the revenues from the sale.

In addition to the above, we reviewed the accounting literature and submit that our business is not dissimilar to that of a real-estate developer who acquires vacant land with the intention of selling it.  The authoritative literature on this type of transaction is SFAS 66 "Accounting for Sales of Real Estate."  Appendices of SFAS 66 provide several examples where the cash proceeds from a completed sale of land are required to be reported as revenues.  Land sales in the context of real estate (as is our mineral property) are revenue.  We believe when we sell mineral property, it is revenue.  We believe that reporting the sale of our mineral property as a gain (or loss) on discontinued operations does not reflect our business and we can find no direct support for such treatment from our review of the relevant accounting literature.

Other "significant revenues" as defined in SFAS 7, paragraph 8(b)

On December 23, 1996, we signed a joint venture agreement with Cominco, Ltd of Vancouver, BC, Canada on our Bongará property, which we still own today.  As part of that agreement, Cominco paid Solitario $250,000 cash on signing.  In addition, Cominco paid us $354,000 in January 1998 as part of that joint venture, $118,000 in January 1999, and $118,000 in January 2000.  These payments were directly to Solitario and were in addition to approximately $17,000,000 in direct exploration expenditures by Cominco on the property.  The total cash payments directly to Solitario as part of this joint venture were $840,000.  Solitario recorded $200,000 in revenues from these cash payments, pursuant to our policy on mineral property and joint ventures as disclosed in Note 2 to our financial statements in 2000, which states:

 "The Company records the proceeds from the sale of property interests to joint ventures as a reduction of the related property's capitalized cost.  Proceeds which exceed the capitalized cost of the property are recognized as revenue.  When such proceeds are associated with properties subject to a joint venture, they are recorded as revenue in accordance with the terms of the joint venture and the transfer of the property interest to the joint venture partner during the term of the joint venture."

As discussed below, we believe the $840,000 in payments and the related revenues of $200,000, which were recorded in 1999 and 2000 meet the definition of "significant revenues" as used in the context of paragraph 8(b).  Our Bongará project was being held for sale or joint venture.  We never relinquished

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control of the property as Cominco dropped out of the project, before earning any interest.  Accordingly, we believe it would be inappropriate to change our accounting policy, which has been in effect since 2000, to record the receipts from the Cominco joint venture as anything other than revenue.

In addition, we entered into two different joint venture agreements at our Yanacocha property prior to its ultimate sale discussed above; one in 1995 with Barrick Gold Corporation of Toronto, Canada and one in 1997 with RTZ-CRA of London, England.  Although both of these joint ventures were eventually terminated as our joint venture partners dropped out prior to earning any interest in the property, we received joint venture payments of $100,000 from those joint ventures, which were used to offset capitalized costs in accordance with our stated policy at that time, which included capitalizing exploration costs.  These payments were in addition to approximately $1,250,000 of direct exploration expenditures on the Yanacocha property during the term of these joint ventures by our joint venture partners.

We also believe it is important to note that all exploration costs must be expensed according to accounting principles generally accepted in the United States of America and our current policy, which we adopted in 2000 as a change in accounting principle.  Therefore in applying the inception-to-date disclosures of paragraph 11 of SFAS 7, approximately $850,000 of the above joint venture payments of $940,000 on our Bongará project and our Yanacocha property would be recorded as revenues on proceeds in excess of capitalized (initial acquisition) costs, which totaled approximately $90,000 on the two properties.  Accordingly, we believe identifying Solitario as a development stage enterprise would