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  International Aluminum Corporation

  767
  Monterey Pass Road

  Phone:

  (323)
  264-1670

  Monterey
  Park, CA 91754

  Fax:

  (323)
  260-7605

February 23, 2005

Mr. Rufus Decker,
Accounting Branch Chief

Division of Corporation
Finance

Securities And Exchange
Commission

450 Fifth Street, N.W.

Washington, D.C.  20549-0510

                Re:
International Aluminum Corporation,
File No. 1-7256

Dear Mr. Decker:

This letter responds to
your letter addressed to Mr. Cornelius C. Vanderstar of International Aluminum
Corporation, dated January 26, 2005.
Your letter requests supplemental information relating to the review by
your staff of our Form 10-K for the fiscal year ended June 30, 2004 and our
Form 10-Q for the quarter ended September 30, 2004.

Cover
Page

2.     In
future filings, we will correct the disclosure on the Cover Page of all Form
10-Ks to disclose the market value of shares held by non-affiliates as of the
last business day of our most recently completed second quarter.  As of December 31, 2003, such value was
$63,139,110.

Employees,  page 3

3.     In
future Form 10-Ks, we will disclose which of our employees are covered by
collective bargaining agreements.

Item
9A, Controls and Procedures,  page 7

4.     In
future Form 10-Ks, we will state that the evaluation date was as of the end of
the period covered by the report.  This
change was already implemented in our Form 10-Q for the first quarter ended
September 30, 2004 (see page 11) and Form 10-Q for the second quarter ended
December 31, 2004 (see page 12).

Letter
to Shareholders

5.     In
future Annual Reports, we will state the source of market data where
appropriate.

Significant
Changes in Results of Operations,  page 4

6.     In
future Form 10-Ks, and as already implemented in our Form 10-Q for the quarter
ended December 31, 2004 (see pages 9 - 11), we will structure our comments by
segment and discuss in greater detail the business reasons for the changes
between periods.  We also will quantify
the amount of the change attributable to each business reason where
appropriate.

Liquidity
and Capital Resources,  page 6

7.     We
were aware of this requirement, but excluded the table on the basis that the
only applicable amounts relate to operating lease commitments for real estate,
which are insignificant in amount and already disclosed in the Commitments note
on page 15.  We will include a table of
contractual obligations in the future if there are significant contractual
obligations to be disclosed under Item 303(a)(5).

Note
1,  Significant Accounting Policies and
Procedures,  page 13

8.     In
future Form 10-Ks, and as implemented in our Form 10-Q for the quarter ended
December 31, 2004 (see page 9, General Overview, paragraph 2), we will include
a description of the type of costs included in Cost of Goods Sold, including
specific mention of in-bound freight, purchasing, receiving, inspection,
warehousing and distribution costs as appropriate.

Revenue
Recognition,  page 13

9.     In
future Form 10-Ks, we will specifically disclose that our shipping terms are
FOB shipping point.  Our sales agreements
and practices are consistent with FOB shipping point.  Our sales agreements do not contain right of
inspection or acceptance provisions, and we do not replace goods that are
damaged or lost in transit.

Stock
Based Compensation,  page 14

10.  We were aware of this requirement, but did
not include the earnings reconciliation, earnings per share reconciliation or
other disclosures since there would have been no impact on current earnings or
earnings per share had compensation cost been determined based on the fair
value at the grant dates as prescribed by SFAS 123.  In future Form 10-Ks, and as implemented in
the Form 10-Q for the quarter ended December 31, 2004 (see page 7) we will
include additional disclosure that clarifies that there would have been no
impact.  Of course, we also will include
the earnings reconciliation and the other disclosures in the future if there
are stock awards that would create a difference in reportable earnings or
earnings per share under the fair value method.

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Note
2,  Balance Sheet Components,  page 14

11.  In future Form 10-Ks, we will break out two
additional components:  Office
Equipment/Computers and Vehicles.  The
remaining Machinery and Equipment, while having a broad range of useful lives,
cannot logically be broken down into smaller components since the remaining
balance is Production Equipment with varying useful lives.

Note
6,  Earnings Per Share,  page 16

12.  In future Form 10-Ks, and as implemented in
the Form 10-Q for the quarter ended December 31, 2004 (see page 7), we will
disclose the securities that could potentially dilute basic EPS but were not
included in the computation of diluted EPS because to do so would have been
antidilutive for the periods presented.

Note
10,  Segment Information,  page 18

13.  We were aware of this requirement, but did
not include tax expense for each segment as it was not applicable.  The Company evaluates performance based on
operating income or loss before the allocation of corporate overhead, interest
or taxes.  Taxes are not calculated on an
individual entity or segment basis.

Form
10-Q

14.  Form 10-K comments that also relate to the
Form 10-Q have been addressed in each comment above.

In addition to the
foregoing, the Company acknowledges that it:

•                  is responsible for the adequacy and accuracy of the
disclosure in its filings;

•                  is informed of the staff’s position that staff
comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any action with respect to the Company’s
filings; and

•                  is informed of the staff’s position that 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.

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I believe this fully
addresses each of your comments and fulfills your requests for supplemental
information.  If you or your staff have
further questions, please contact the undersigned.

Sincerely,

INTERNATIONAL ALUMINUM
CORPORATION

Mitchell K. Fogelman

Sr. Vice President —
Finance

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