MADISON OPPORTUNITY FUND INC
N-30D, 1997-09-10
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MADISON OPPORTUNITY FUND, INC.
Semi-Annual Report 
June 30, 1997
(unaudited)
608-274-0300
6411 Mineral Point Road
Madison, WI  53705

STATEMENT OF NET ASSETS 
Schedule of Investments
June 30, 1997
                                            Market
Common Stocks - 85.1%              Shares	  Value	

Basic Industry -3.5%
Morton International, Inc.         800      $ 24,150

Consumer Cyclical - 8.2% 
Callaway Golf Co.                  600        21,300
Clayton Homes, Inc.                937        13,352
Tommy Hilfiger Corp.               550        22,103

Consumer Services - 7.1%
LaQuinta Inns                    1,250        27,344
Unitog Co.                         800        21,600

Consumer Staples - 2.4% 
Richfood Holdings, Inc.            650        16,900

Consumer Retail - 10.0%
Intimate Brands, Inc.            1,200        25,200
Officemax, Inc.                  1,300        18,769
Pep Boys - Manny Moe & Jack        750        25,547

Financial -Insurance - 5.9%
ALLIED Group                       450        17,100
MGIC Investment                    500        23,969

Financial Services - 13.9% 
Equifax, Inc.                      650        24,172
Franklin Resources, Inc.           350        25,397
Green Tree Financial Corp.         750        26,719
United Asset Management            700        19,819

Food & Beverage - 4.0%
Dole Food Co.                      650        27,787

Medical & Health Care - 16.0%
Dentsply International, Inc.       400        19,600
Express Scripts, Inc.              500        20,875
Health Care Compare                450        23,569
Sybron International Corp.         600        23,925
Watson Pharmaceutical              550        23,237

Technology - Hardware - 6.8%
Cabletron Systems, Inc.            400        11,325
EMC Corp/Mass                      425        16,575
IKOS Systems, Inc.                 900        19,237

Technology - Semiconductors/Electronics - 2.5%
Arrow Electronics, Inc.            325        17,266

Technology - Software - 4.8% 
CFI Proservices, Inc.              750        13,500
Fiserv, Inc.                       450        20,081

Total Common Stocks (cost $500,940)	        $590,418
See Accompanying Notes to Financial Statements

<PAGE>
MADISON OPPORTUNITY FUND, INC.
STATEMENT OF NET ASSETS (continued)



	


				
				Principal			Market
		 		Amount			Value	
Short Term Investments - 17.9%


Repurchase Agreement:  % of Net Assets
With DLJ Securities issued 6/30/97 at 5.75%
  due 7/1/97                                  $124,000


	

Cash & Receivables Less Liabilities - (-.3.0%)$(20,619)

TOTAL NET ASSETS - Equivalent to $23.77 per share on 29,175.874 shares 
of $.01 par value capital stock outstanding (authorized capital stock - 
500,000 shares), and paid in capital aggregated $591,858.  $693,799


	

















				
See Accompanying Notes to Financial Statements
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<PAGE>
MADISON OPPORTUNITY FUND, INC.
STATEMENT OF OPERATIONS


               Six Month Period Ended
                 June 30, 1997		

Income:
Interest           $   3,051	
Dividends              1,844	
                 $     4,895
Expenses:
Investment Advisor Fee  $215
Auditing Fee           1,123
Custodial Fee            519
Legal Fee                215
Transfer Agent Fee       410
Licensing Fee            100
Other Fees               171	
                      $2,753	


Net Investment Income $2,142	

Ratio of Expenses to Income  56.2%		



Realized Gains on Investments:
Proceeds from Sale  $224,193	
Cost                 214,858	
Net Realized Gains $   9,335	



Unrealized Appreciation on Investments:  
Balance, Beginning of Year             $42,374	
Balance, End of Year                    89,478	
Increase in Unrealized Appreciation    $47,104



Net Realized Gains and Increase
in Unrealized Appreciation             $56,439	











See Accompanying Notes to Financial Statements.
4
<PAGE>
MADISON OPPORTUNITY FUND, INC.
STATEMENT OF CHANGES IN NET ASSETS

				
                          Six Month Period Ended  Year Ended
                                   June 30, 1997  December 31, 1996

Investment Activities
Net Investment Income                 $2,142      $6,562
Income Distributions to Shareholders       0       5,866
	
  Increase in Undistributed Net 
  Investment Income                   $2,142         696

Net Realized Gains from Security
 Transactions                         $9,335      28,361
Net Realized Gain Distributions to
 Shareholders                              0     (28,362)

		
 Increase (Decrease) in Undistributed
   Realized Gains                     $9,335          (1)


Increase in Unrealized Appreciation  $47,104      42,374

Increase in Undistributed Net Assets
  Derived From Investment Activities $58,581      43,069


Shares Sold and Redeemed
Net Proceeds from Shares Issued           $0     157,921 
Net Asset Value of Shares Issued in
  Distributions                            0      34,228
		
	
Cost of Shares Redeemed	$                  0           0


Increase in Net Assets from Sale of
  Fund Shares                             $0     192,149


Net Assets
Balance at Beginning of Year        $635,218     400,000
Net Increase from Investment 
  Activities                          58,581      43,069
Net Increase from Shares Sold and Redeemed 0     192,149

			
Balance at End of Year (Including
 undistributed net investment
 income of $3,234)                  $693,799     635,218
 

See Accompanying Notes to Financial Statements.
5
<PAGE>

MADISON OPPORTUNITY FUND, INC.


FINANCIAL HIGHLIGHTS - Selected Per Share Data and Ratios	
	
                                        Period Ended   Year Ended 
                                       June 30, 1996   December 31, 1996

NET ASSET VALUE:	
   Beginning of year........................  $ 21.77   20.00 
INCOME FROM INVESTMENT OPERATIONS:	
   Net investment income...................  $   0.07    0.24 
   Net realized and unrealized gains	
   or (losses) on securities...............  $   1.93    2.77 
   Total from investment operations........  $  23.77   23.01   
LESS DISTRIBUTIONS:	
   Dividends from net income...............  $     --   (0.21)	
   Capital gains distributions.............  $     --   (1.03)	
NET ASSET VALUE:		
   End of year............................   $  23.77   21.77 	
TOTAL RETURN:                                    9.19%  15.05%	
RATIOS:		
   Operating expenses to average net assets.     0.85%*  0.81%	
   Net income to average net assets.........     0.67%   1.20%	
   Portfolio turnover rate....................  34.59%  56.52%	
   Average commission rate paid...............   0.08      --	

*Annualized
<PAGE>
MADISON OPPORTUNITY FUND, INC.	
NOTES TO FINANCIAL STATEMENTS    June 30, 1997 (unaudited)

(1)  Significant Accounting Principles
Madison Opportunity Fund, Inc. began operations on December 27, 1995.  
There were no operations in 1995 and net assets consisted soley of  
$400,000 for the purchase of 20,000 shares by investors.  The Fund is 
registered under the Investment Company Act of 1940, as amended, as an 
open-end management company.  The Fund is not publicly offered and is 
not registered under the Securities Act of 1933.  The following is a 
summary of significant accounting principles followed by the Fund in the 
preparation of its financial statements.  The policies are in conformity 
with generally accepted accounting principles.

(a)  The market quotation for each security is the last reported sale 
price on a national securities exchange, or, in the case of Over-The-
Counter securities, the latest available bid price. Other securities for 
which quotations are not readily available are valued at fair value as 
determined by the Board of Directors. Short-term securities (maturing 
within 60 days) are valued on the basis of amortized cost. Securities 
with  maturities in excess of 60 days are valued at market value.

(b)	No provision is made for Federal income taxes since it is the 
intention of the Fund to comply with the provisions of the Internal 
Revenue Code available to investment companies, and to make the 
requisite distribution to shareholders of taxable income which will be 
sufficient to relieve it from all or substantially all Federal income 
taxes.

(c)	All percentages for the various classifications relate to total 
net assets.

(d)	The Fund follows industry practice and records security 
transactions on the trade date.  Dividend income is recognized on the 
ex-dividend date and interest income is accrued on a daily basis.

(2)       Investment Advisory Agreement
The investment advisory agreement with Madison Investment Advisors, 
Inc., provides for an annual management fee of .75 of 1% on the average 
net assets of the Fund.  Such fees were being waived until June 16, 
1997. Although the investment advisor may be reimbursed for clerical or 
administrative expenses incurred by it, none have been charged to the 
Fund during 1996 and 1997. Certain officers and directors of the Fund 
are also officers and directors of Madison Investment Advisors, Inc.

(3)	Cost of Investments Purchased and Proceeds of Investments Sold
For the six month period ended June 30, 1997, the purchases and sales of 
investment securities (excluding short-term securities) were $237,046 
and $224,193, respectively, (purchases and sales of U.S. government 
obligations only were $0 and $0, respectively).

(4)	Aggregate Cost of Securities and Undistributed Income or Capital 
Gains
The aggregate cost of securities for Federal income tax purposes is 
$603,965. The aggregate gross unrealized appreciation for all securities 
in which there is an excess of value over tax cost is $95,067. The 
aggregate gross unrealized depreciation for all securities in which 
there is an excess of tax cost over value amounts to $5,589.          
The net unrealized appreciation at June 30, 1997, for all securities is 
$89,478. Through the year ended June 30, 1997, the accumulated 
undistributed net investment income is $3,234, and the accumulated 
undistributed realized capital gain is 9,334.




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