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SEC Company Response from Idaho Strategic Resources, Inc. (IDR) (CIK 0001030192) (IDR) — Feb 8, 2008

Idaho Strategic Resources, Inc. (IDR) (CIK 0001030192)
Date: Feb. 8, 2008 · CIK: 0001030192 · Accession: 0001062993-08-000471

AI Filing Summary & Sentiment

Date
February 6, 2008
Author
Fred W. Brackebusch
Form
CORRESP
Company
Idaho Strategic Resources, Inc. (IDR) (CIK 0001030192)

Letter

United States Securities and Exchange Commission Division of Corporation Finance 100 F Street, NE Mail Stop 7010 Washington, D.C. 20549-7410

Dear Ms. Davis:

Following are responses to the SEC’s comments faxed to our office on February 6, 2008 relating to the Company’s 2006 Form 10-KSB filed March 28, 2007 and 2007 Form 10QSB for Fiscal Quarter Ended September 30, 2007 filed November 13, 2007. These comments are specifically regarding our response to your original comments and the associated amended Form 10KSB filed as correspondence on January 10, 2008. We have discussed our planned responses with internal staff and with our auditors and submit the following responses: I believe we have responded fully to the comments made by SEC. A marked filing of the proposed revisions to the Form 10-KSB is included for reference.

Form 10-KSB for the Fiscal Year Ended December 31,

Statement of Operations, page 30

1.

Comment: We note from your response to prior comment number two that you will expand your accounting policy footnote to indicate that “Other income and expense transactions are presented at net unless they are material, in which case they are separated as unique expense and revenue items.” Please revise your proposed policy to reference, instead, your accounting policy with respect to timber sales and why you reflect them as net. In this regard, we note from your response that these sales are not a normal part of your business but instead appear to be the result of peripheral or incidental transactions.

Response: We have, upon further reflection, decided to present our timber revenue and expense as separate items on the statement of operations. Additionally we have revised our policy footnote on page 35 to specifically discuss Timber sales.

2.

Comment: Additionally, it appears from your revised disclosure that your policy decision on whether to present items gross or net is a matter of materiality. Please cite the authoritative literature you are relying on in support of this position or otherwise clarify your accounting policy as necessary.

Response: We have removed any mention of materiality from our policy and are now presenting timber sales as gross.

3.

Comment: Finally, please briefly describe the nature of your involvement in timber sales, including the assets you own that contribute the timber, and how and when you generate these sales.

Response: The Company has about 70 acres of timberland associated with its Coleman Mine property upon which logging campaigns occur on a 10-15 year cycle. Logging operations will be conducted by hiring independent contractors to cut and haul the logs to local markets.

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,
Fred W. Brackebusch
President

Show Raw Text
CORRESP
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   Filed by Automated Filing Services Inc. (604)609-0244 - New Jersey Mining Company - Response Letter

New Jersey Mining Company
P.O. BOX
1019
KELLOGG, ID 83837
(208) 783-3331 [PHONE OR FAX]

    February 6, 2008

    Revised February 8, 2008

    Jill S. Davis, Branch Chief

    United States Securities and Exchange Commission

    Division of Corporation Finance

    100 F Street, NE

    Mail Stop 7010

    Washington, D.C. 20549-7410

Dear Ms. Davis:

Following are responses to the SEC’s comments faxed to our
office on February 6, 2008 relating to the Company’s 2006 Form 10-KSB filed
March 28, 2007 and 2007 Form 10QSB for Fiscal Quarter Ended September 30, 2007
filed November 13, 2007. These comments are specifically regarding our response
to your original comments and the associated amended Form 10KSB filed as
correspondence on January 10, 2008. We have discussed our planned responses with
internal staff and with our auditors and submit the following responses: I
believe we have responded fully to the comments made by SEC. A marked filing of
the proposed revisions to the Form 10-KSB is included for reference.

Form 10-KSB for the Fiscal Year Ended December 31,
2006

Statement of Operations, page 30

    1.

      Comment: We note from your response to prior comment
      number two that you will expand your accounting policy footnote to
      indicate that “Other income and expense transactions are presented at net
      unless they are material, in which case they are separated as unique
      expense and revenue items.” Please revise your proposed policy to
      reference, instead, your accounting policy with respect to timber sales
      and why you reflect them as net. In this regard, we note from your
      response that these sales are not a normal part of your business but
      instead appear to be the result of peripheral or incidental
      transactions.

      Response: We have, upon further reflection, decided to
      present our timber revenue and expense as separate items on the statement
      of operations. Additionally we have revised our policy footnote on page 35
      to specifically discuss Timber sales.

    2.

      Comment: Additionally, it appears from your revised
      disclosure that your policy decision on whether to present items gross or
      net is a matter of materiality. Please cite the authoritative literature
      you are relying on in support of this position or otherwise clarify your
      accounting policy as necessary.

1

      Response: We have removed any mention of materiality from
      our policy and are now presenting timber sales as gross.

    3.

      Comment: Finally, please briefly describe the nature of
      your involvement in timber sales, including the assets you own that
      contribute the timber, and how and when you generate these
sales.

      Response: The Company has about 70 acres of timberland
      associated with its Coleman Mine property upon which logging campaigns
      occur on a 10-15 year cycle. Logging operations will be conducted by
      hiring independent contractors to cut and haul the logs to local
      markets.

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,

Fred W. Brackebusch
President

2