One Atlantic Center
1201 West Peachtree Street
Atlanta, GA 30309-3424
1201 West Peachtree Street
Atlanta, GA 30309-3424
404-881-7000
Fax: 404-881-7777
www.alston.com
Fax: 404-881-7777
www.alston.com
Paul J. Nozick
|
Direct Dial: 404-881-7451 | Email: paul.nozick@alston.com |
December 19, 2011
VIA EDGAR
Adam F. Turk, Attorney-Advisor
Division of Corporation Finance
Securities and Exchange Commission
100 F. Street, N.E.
Washington, D.C. 20549
Division of Corporation Finance
Securities and Exchange Commission
100 F. Street, N.E.
Washington, D.C. 20549
| Re: | Apartment Investment and Management Company AIMCO Properties, L.P. Registration Statement on Form S-4 Filed July 28, 2011 File No.: 333-175850 |
Dear Mr. Turk:
Apartment Investment and Management Company (“Aimco”) and AIMCO Properties, L.P.
(“Aimco OP”) are today filing an amendment to the Registration Statement (File
No. 333-175850) on Form S-4 (the “CPF XV Form S-4”) referenced above. The CPF XV Form S-4
relates to the merger of Century Properties Fund XV, LP.
We hereby confirm, on behalf of Aimco and Aimco OP, that the changes made to the CPF XV Form
S-4 are similar in nature to those that were previously made by Aimco and Aimco OP in the
amendments to three Registration Statements on Form S-4 (File Nos. 333-175843, 333-175848 and
333-175853), filed with the Securities and Exchange Commission on November 15, 2011 (the “Prior
Filings”). The changes made to the CPF XV Form S-4 (including opinions filed as exhibits)
respond to the Staff’s comments in the same manner as the Prior Filings.
* * * *
If you have any questions regarding the foregoing, please contact the undersigned at (404)
881-7451.
Atlanta • Brussels • Charlotte • Dallas • Los Angeles • New York • Research Triangle • Silicon Valley • Ventura County • Washington, D.C.
December 19, 2011
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Respectfully yours,
/s/ Paul J. Nozick
Paul J. Nozick
Paul J. Nozick
| cc: | John Bezzant, Executive Vice President Apartment Investment and Management Company Trent Johnson, Vice President and Assistant General Counsel Apartment Investment and Management Company |