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
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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.
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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
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