SecProbe.io

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 April 30, 2025

Grant Brackebusch
Chief Financial Officer
Idaho Strategic Resources, Inc.
201 N. Third Street
Coeur d Alene, ID 83814

 Re: Idaho Strategic Resources, Inc.
 Form 10-K for the Fiscal Year ended December 31, 2024
 Filed March 31, 2025
 File No. 001-41320
Dear Grant Brackebusch:

 We have reviewed your filing and have the following comments.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 10-K for the Fiscal Year ended December 31, 2024
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations, page 40

1. We note your disclosure indicating that revenue from concentrate sales
in 2024
 increased 88.7% compared to 2023 due to multiple factors, including more
ounces of
 gold sold as well as higher gold prices during the more recent period.

 Please expand your discussion and analysis of revenue to separately
quantify
 the change in revenue that is attributable to (i) the change in the
price of gold and (ii)
 the change in quantities sold, to comply with Item 303(b)(2)(iii) of
Regulation S-X.

 To provide context for the discussion and analysis, regarding the impact
that changes
 in gold prices have had on your revenues, please include the average
realized gold
 prices for the years ended December 31, 2023 and 2024.
 April 30, 2025
Page 2

Cash Costs and All-In Sustaining Costs Reconciliations to Generally Accepted
Accounting
Principles ("GAAP"), page 41

2. We note your disclosure of the non-GAAP measure, All-in Sustaining Costs
 (AISC), indicating you changed the manner of computation in 2024.

 Please expand your disclosure to describe the types of expenditures that
you regard as
 sustaining capital, versus non-sustaining capital, for purposes of
calculating AISC, to
 include the distinguishing characteristics and your rationale.

Controls and Procedures
Disclosure of Controls and Procedures, page 42

3. We note your disclosure stating that your President also serves as your
Chief
 Accounting Officer and has evaluated the effectiveness of the design and
operation of
 your disclosure controls and procedures.

 However, you have disclosure on page 43 identifying a separate
individual who
 serves as Chief Financial Officer, and you have filed certifications
that pertain to
 such evaluation at Exhibits 31.1 and 31.2, indicating that both your
President/Chief
 Executive Office and the Chief Financial Officer were involved.

 Please revise your disclosure to clarify the role of both officers in
evaluating the
 effectiveness of your disclosure controls and procedures, whose
participation would
 ordinarily be required to comply with Item 307 of Regulation S-K.

Financial Statements
Note 2 - Summary of Significant Accounting Policies
Mine Exploration and Development Costs, page F-9

4. We note that you amortize acquisition costs for mineral properties using
the unit of
 production method based on estimated reserves although you amortize
development
 costs based on estimated recoverable resources.

 Please revise as necessary to address the following points regarding
your amortization
 base and accounting policy for development costs:

 Clarify whether the measure of resources being utilized is
inclusive of reserves.

 Describe the reasons that proven and probable reserves alone are
not utlized as the
 basis for computing the amortization of development costs.

 Identify the types of resources that are included in the
amortization base, as to any
 measured, indicated and inferred resources.
 April 30, 2025
Page 3

 Explain how the amortization base reflects the differing levels of
confidence
 among the various categories of reserves and resources.

 If inferred resources are included in the amortization base, tell us how
the level of
 uncertainty about tonnage, grade and mineral content, and the
corresponding low level
 of confidence as to economic producibility, were considered in deciding
that inclusion
 would be consistent with the general requirement in FASB ASC 360-10-35,
to
 allocate cost over the expected useful life in a systematic and rational
manner.

 With regard to any category of resources included within the
amortization base,
 clarify how you considered the different levels of confidence attributed
to each of the
 three categories of resources within the corresponding definitions in
Item 1300 of
 Regulation S-K, in determining the base represented an appropriate
useful life.

Exhibits

5. The certifications at Exhibits 31.1 and 31.2 should be modified as
necessary to adhere
 to the prescribe language in Item 601(b)(31) of Regulation S-K. For
example,
 paragraphs 4 and 5 should include the phrase "The registrant s other
certifying
 officer(s) and I" to acknowledge the joint effort that is required.

 We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.

 Please contact Jenifer Gallagher at 202-551-3706 or Gus Rodriguez at
202-551-3752
if you have questions regarding comments on the financial statements and
related matters.

 Sincerely,

 Division of
Corporation Finance
 Office of Energy &
Transportation
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