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 May 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
 Response Dated May 14, 2025
 File No. 001-41320
Dear Grant Brackebusch:

 We have reviewed your May 14, 2025 response to our comment letter 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.
Unless we note otherwise, any references to prior comments are to comments in
our April 30,
2025 letter.

Form 10-K for the Fiscal Year ended December 31, 2024
Cash Costs and All-In Sustaining Costs Reconciliations to Generally Accepted
Accounting
Principles ("GAAP"), page 41

1. We note your response to prior comment 2 stating that sustaining capital
adjustments
 made in computing AISC include depreciation that sustains production
 activities although you do not indicate the extent to which
depreciation and
 amortization correlates with that criteria or identify the other
components, and you
 have not submitted any proposed disclosure revisions.

 Given that your depreciation and amortization expense was $1,953,388 and
 $1,466,703 for 2024 and 2023, while your sustaining capital
adjustment was
 $3,385,893 and $2,458,737 for these periods, further details appear to
be necessary to
 adequately describe the composition of the adjustments.
 May 30, 2025
Page 2

 Please expand your disclosure to explain how the sustaining capital
adjustments are
 calculated or estimated for each period, and provide specific details
about the change
 in computation made in 2024, including quantification of the items
involved and your
 rationale. Please clarify whether you regard all of the depreciation and
amortization
 reported in the financial statements as a component of this adjustment or
only a
 portion, and explain how the amount included was determined to have the
quality of
 sustaining production activities, considering that it is a historical
cost and the ability to
 sustain future production activities implies an incremental future cost.

 Please identify the other components that comprise your sustaining
capital
 adjustments and explain how these components have changed each period and
state
 the reasons. We reissue prior comment 2.

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

2. We understand from your response to prior comment 4 that you have used
combined
 estimates of inferred, indicated, and measured resources as well as
proven and
 probable reserves in calculating depreciation and amortization expense,
and that you
 intend to include disclosure that would describe this as utilizing a
systematic manner
 of recoverable tonnes of mineral resources and reserves, although you
propose to
 discontinue the practice of including inferred resources in the
computation.

 Please explain to us whether your reference to recoverable tonnes
is correlated with
 any historical adjustments to the resource and reserve estimates in
determining the
 quantities utilized in your calculations of depreciation and amortization
expense.

 Given the criteria in FASB ASC 360-10-35-4, requiring an allocation of
costs over the
 expected useful life of the asset in a systematic and rational
 manner, your
 accounting policy related to depreciation and amortization expense should
clarify the
 extent to which resources that are excluded from the cash flow analyses
and life-of-
 mine plans underlying estimates of proven and probable reserves in the
technical
 report summary, are nevertheless considered to be part of the expected
useful life of
 the mine in allocating costs that have been capitalized (based on the
units-of-
 production method), along with your rationale and representation in this
regard.

 Under these circumstances you should also discuss this approach as a
critical
 accounting policy in MD&A, along with further details of your rationale,
to include
 material assumptions and uncertainties. For example, discuss the nature
and type of
 mineralization, the degree to which continuity has been established,
drill hole spacing
 for the respective resource categories, extent of interpolation vs.
extrapolation applied
 in the estimatations, and extent of recent conversions of resources to
reserves.
 May 30, 2025
Page 3

 If your expectations of useful life involve assumptions based on matters
that are
 highlty uncertain and reasonably likely to change, these should be
identified and
 discussed in terms of their particular sensitivity to change, and
updated each period to
 identify any material instances of actual experience that does not align
with those
 assumptions and the implications. If you include resource quantities for
which either
 economic viability has not been established, or a decision to mine has
not yet been
 made, further details should be provided to clarify why these are
appropriately
 considered to be part of the expected useful life of the mine, in your
view.

 Given the different levels of uncertainty associated with each category
of resources,
 also clarify the extent to which you have risk adjusted the volumes, as
would appear
 to be necessary in establishing an appropriate view on the expected
useful life of the
 mine, for use in your calculations of depreciation and amortization
expense.

 Please submit the revisions that you propose to each section of the
filing to address
 the concerns outlined in each comment above along with your response.

 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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