June 21, 2005

VIA EDGAR & HAND DELIVERY


Abby Adams, Esq.
Office of Mergers and Acquisitions
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, N.W.
Washington, D.C.  20549


                Re:      FOX STRATEGIC HOUSING INCOME PARTNERS AND CENTURY
                         PROPERTIES FUND XV
                         AMENDED SCHEDULE TO-T/13E-3S
                         FILED JUNE 7, 2005 BY AIMCO PROPERTIES LP, ET AL.


Dear Ms. Adams:

         On behalf of AIMCO Properties, L.P. ("AIMCO OP"), we are responding to
the Staff's comment letter, dated June 16, 2005, regarding the Tender Offer
Statements and Rule 13e-3 Transaction Statements on Schedule TO referred to
above. AIMCO OP is in the process of gathering the additional information
requested by the Staff. However, in the interest of accelerating your review
process and disseminating revised disclosures promptly, we have filed an
amendment to the Schedule TO for each of Century Properties Fund XV and Fox
Strategic Housing Income Partners, which reflects the revised disclosure in
response to comment number 7 of the Staff's letter, dated June 16, 2005. AIMCO
OP intends to respond to the Staff's remaining comments in a subsequent letter
and to file amendments to the Schedule TO for each of Century Properties Fund
XIX, Davidson Income Real Estate, L.P. and National Property Investors III as
soon as practicable. We have set forth below the Staff's comment referenced
above and AIMCO OP's response to such comment.

Fox Strategic Housing Income Partners
Century Properties Fund XV

     7.  We note the information added in this amendment regarding prior
         purchases by Mr. Ira Gaines. Tell us whether these purchases were
         through a tender offer. If so, it appears that you should revise the
         table on page 14 to reflect this tender offer.

         RESPONSE: AIMCO OP supplementally advises the Staff that these
         purchases were effected through tender offers. We have revised the
         disclosure in response to this comment.






Securities and Exchange Commission
June 21, 2005
Page 2


         We would appreciate your prompt attention to this letter. Please do not
hesitate to contact the undersigned at (213) 687-5527 or Jonathan Friedman at
(213) 687-5396 if you have any questions or comments regarding this letter.


                                             Very truly yours,

                                             /s/ JONATHAN KO

                                             Jonathan Ko


cc:      Daniel L. Jablonsky, Esq. - Securities and Exchange Commission,
         Division of Enforcement
         Martha Long - Apartment Investment and Management Company
         Miles Cortez, Esq. - Apartment Investment and Management Company
         Joseph Coco, Esq. - Skadden, Arps, Slate, Meagher & Flom LLP
         Jonathan Friedman, Esq. - Skadden, Arps, Slate, Meagher & Flom LLP