SecProbe.io

CORRESP
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  Phone:  (323) 264-1670

  Fax:   (323) 260-7605

April 8, 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 March 2, 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, our Form 10-Q for the
quarter ended September 30, 2004 and our response to your letter dated January
26, 2005.

Letter
to Shareholders

1.               In
future Annual Reports, we will state the source of any market data as well as
the basis for any statement of our percentage of the market.

Significant Changes in
Results of Operations,  page 4

2.               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 discussion of
results of operations by business segment and discuss in appropriate 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.

As requested, the
following is a draft of the discussion of our results of operations for the
year ended June 30, 2004 as compared to June 30, 2003 that will appear in our
next Form 10-K.

MANAGEMENT’S DISCUSSION AND ANALYSIS OF

FINANCIAL CONDITION AND RESULTS OF OPERATIONS

Significant Changes in Results of Operations

2004 vs. 2003

General Overview

Net
sales for fiscal 2004 increased $20,485,000 or 10.6% from fiscal 2003.  All Groups achieved increased sales during
2004 compared to the prior year.  Gross
profit increased to 20.6% of sales in 2004 compared to 18.4% in 2003.  All Groups realized reductions, to varying
degrees, in their cost of sales percentages during fiscal 2004 compared to the
prior year.  Selling, general and
administrative expenses increased $5,107,000 to 15.8% of sales in fiscal 2004
compared to 14.8% in fiscal 2003.

The
Company includes product costs, inbound freight, purchasing, receiving,
inspection, internal transfer, warehousing and other costs of the Company’s
distribution network in cost of goods sold, thereby reducing gross profit by
these amounts.  Cost of sales and gross
profit as a percent of sales for the Company may not be comparable to those of
other companies in our industry since other entities may record purchasing,
warehousing and distribution costs as Selling, General and Administrative
expense.

The
contribution to these results by each segment is discussed below.

Residential Products

Sales
of the Residential Products Group increased $11,361,000 or 21.2% compared to
the 2003 year.  Low mortgage interest
rates and increased consumer confidence continued to stimulate new home
construction, resales of existing homes and home improvement spending during
fiscal 2004.  In addition, sales at our
South Gate, California facility continue to improve due to our success in
restoring customer confidence in our product quality and customer service that
had suffered during the prolonged strike in fiscal 2002.  New product development and new marketing and
advertising programs have also contributed to the increased sales of this
Group.  Gross profit increased to 29.1%
of sales in fiscal 2004 compared to 27.1% in 2003.  This Group experienced decreased material,
labor and overhead cost percentages compared to the prior year reflecting
production efficiencies

attained
from additional automation and the substantially higher sales volume.  Selling, general and administrative expenses
increased $2,502,000 to 13.0% of sales in fiscal 2004 compared to 11.2% of
sales in 2003.  This increase includes
$1,064,000 for retrospective workers’ compensation and general liability
insurance policies, $543,000 for additional employment related to the increase
in sales and attainment of incentive compensation targets, $451,000 for
advertising and promotional costs, and $119,000 for current year general
liability insurance costs.

Commercial Products

Sales
of the Commercial Products Group increased $1,444,000 or 1.5% compared to the
2003 year.  This increase was due to the
substantial gains achieved during the fourth quarter, $4,027,000 or 17.1%
compared to the same period of the prior year.
Throughout most of fiscal 2004 a soft commercial construction market
coupled with increased competitive conditions negatively impacted this
group.  Sales of newly developed product
lines lessened the negative impact.  The
fourth quarter results benefited from increased construction activity, together
with an approximately 6% increase in sales prices.  Gross profit increased to 21.5% of sales in
fiscal 2004 compared to 19.5% in 2003.
This Group achieved lower costs as a percentage of sales compared to
last year mainly due to improved margins generated as a result of the
aforementioned fourth quarter sales increase.
In addition, the prior year had unusually high material costs for some
major projects at the United States Aluminum facility in Texas.  Selling, general and administrative expenses
increased $768,000 to 13.1% of sales in fiscal 2004 compared to 12.6% of sales
in 2003.  This increase was mainly due to
an increase of $459,000 for employment costs related to achievement of
incentive compensation targets, $200,000 for retrospective workers’
compensation and general liability insurance policies and $175,000 for employment
and sales representation costs related to the increase in sales.

Aluminum Extrusion

Sales
of the Aluminum Extrusion Group increased $7,680,000 or 18.5% compared to the
2003 year.  Net tonnage shipped increased
13.9%.  The Extrusion Group continues to
benefit from expanded geographic market penetration, particularly the area
served by our Texas facility.  Although
subject to a highly competitive market, the Group increased sales prices during
the latter part of the year commensurate with the increased cost of
aluminum.  Gross profit increased to 3.8%
of sales in fiscal 2004 compared to 2.5% in 2003.  This Group, while absorbing higher material
costs compared to the prior year, posted decreased labor and overhead cost
percentages primarily due to production efficiencies resulting from the higher
tonnage output.  Selling, general and
administrative expenses increased $657,000 to 3.1% of sales in fiscal 2004
compared to 2.8% of sales in 2003.  This
increase

is
mainly attributable to $478,000 for additional employment and sales
representation costs related to the increase in sales and achievement of
incentive compensation targets.

Corporate

General
and administrative expenses increased $1,180,000 to 4.2% of consolidated net
sales in fiscal 2004 compared to 4.0% in 2003.
The increase was mainly attributable to $907,000 of employee incentive
compensation related to achievement of incentive compensation targets.  It should be noted that the prior year
included $162,000 related to a refund of prior years insurance fees and costs
that served to offset overall expenses.

Interest

The
swing from net interest expense in fiscal 2003 to net interest income in fiscal
2004 relates to increased funds available for investment during the year in
addition to lower utilization of our foreign lines of credit.

Income Taxes

The
effective tax rate increased to 37.7% in fiscal 2004 compared to 35.7% in the
prior year.

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

  /s/ Mitchell K. Fogelman

  Mitchell K. Fogelman

  Sr. Vice President - Finance