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SEC Company Response from Idaho Strategic Resources, Inc. (IDR) (CIK 0001030192) (IDR) — Feb 25, 2008

Idaho Strategic Resources, Inc. (IDR) (CIK 0001030192)
Date: Feb. 25, 2008 · CIK: 0001030192 · Accession: 0001062993-08-000812

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Referenced dates: December 19, 2007

Date
February 25, 2008
Author
Fred W. Brackebusch
Form
CORRESP
Company
Idaho Strategic Resources, Inc. (IDR) (CIK 0001030192)

Letter

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:

We have reviewed all comments relating to your review letters dated December 19, 2007 and February 6, 2008 pertaining 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. Our responses to those comments and proposed amendments to the 2006 Form 10-KSB have been filed as correspondence on January 10, 2008 and February 8, 2008. As we discussed with you via telephone on the morning of February 25, 2008, we recognize and agree with you on the resolutions that are a summation of those two letters. We also agree that the summation of these changes while recognized does not require that an amended Form 10-KSB be filed for 2006 but we will incorporate all changes into our filings from this point forward starting with and including our Form10-KSB for the year ending December 31, 2007.

Summation of Review

Form 10-KSB Filed March 28, 2007

Report of Independent Registered Public Accounting firm, page 27

1.

Our Auditors will continue to exclude from their opinion the inception to date portions of the statements of operations, changes in stockholders’ equity and accumulated comprehensive income, and cash flows. These portions will continue to be labeled “unaudited” in the financial statements.

Statement of Operations, page 30

2.

We will change our presentation of timber revenue and expenses from net to gross and add a timber sales footnote to specifically discuss this portion of our business.

Note 1. Description of Business, page 35

3.

We will change our terminology relating to gold and concentrate sales from “Revenue” to “Income earned during the development stage”. We will also change our revenue policy footnote accordingly.

Note 5. Mineral Properties, page 41

4.

We will no longer make a differentiation between “Deferred Costs” and “Capitalized Development”, Such costs will be referred to as “Deferred Development”. We will also revise our accounting policy footnote relating to Mine Exploration and Development accordingly.

Engineering Comments

Reserves, page 12

5.

We will add a statement to the effect that proven and probable reserves cannot be readily separated to the 10-KSB.

6.

We will use an historic three year gold price in the reserve calculations.

Form 10-QSB for the Fiscal Quarter Ended September 30, 2007

Controls and Procedures, page 11

7.

We will in future filings, state whether or not our disclosure controls and procedures are effective at accomplishing all of the items included within the definition of disclosure controls and procedures as defined in Rule 13a-15(e) of the Exchange Act.

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
1
filename1.htm

   Filed by Automated Filing Services Inc. (604) 609-0244 - New Jersey Mining Co. - Correspondence

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

February 25, 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:

We have reviewed all comments relating to your review letters
dated December 19, 2007 and February 6, 2008 pertaining 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. Our responses to those comments and
proposed amendments to the 2006 Form 10-KSB have been filed as correspondence on
January 10, 2008 and February 8, 2008. As we discussed with you via telephone on
the morning of February 25, 2008, we recognize and agree with you on the
resolutions that are a summation of those two letters. We also agree that the
summation of these changes while recognized does not require that an amended
Form 10-KSB be filed for 2006 but we will incorporate all changes into our
filings from this point forward starting with and including our Form10-KSB for
the year ending December 31, 2007.

Summation of Review

Form 10-KSB Filed March 28, 2007

Report of Independent Registered Public Accounting firm,
page 27

    1.

      Our Auditors will continue to exclude from their opinion
      the inception to date portions of the statements of operations, changes in
      stockholders’ equity and accumulated comprehensive income, and cash flows.
      These portions will continue to be labeled “unaudited” in the financial
      statements.

    Statement of Operations, page 30

    2.

      We will change our presentation of timber revenue and
      expenses from net to gross and add a timber sales footnote to specifically
      discuss this portion of our business.

    Note 1. Description of Business, page 35

    3.

      We will change our terminology relating to gold and
      concentrate sales from “Revenue” to “Income earned during the development
      stage”. We will also change our revenue policy footnote accordingly.

1

    Note 5. Mineral Properties, page 41

    4.

      We will no longer make a differentiation between
      “Deferred Costs” and “Capitalized Development”, Such costs will be
      referred to as “Deferred Development”. We will also revise our accounting
      policy footnote relating to Mine Exploration and Development accordingly.

    Engineering Comments

    Reserves, page 12

    5.

      We will add a statement to the effect that proven and
      probable reserves cannot be readily separated to the 10-KSB.

    6.

      We will use an historic three year gold price in the
      reserve calculations.

    Form 10-QSB for the Fiscal Quarter Ended
      September 30, 2007

    Controls and Procedures, page 11

    7.

      We will in future filings, state whether or not our
      disclosure controls and procedures are effective at accomplishing all of
      the items included within the definition of disclosure controls and
      procedures as defined in Rule 13a-15(e) of the Exchange Act.

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