corresp

One Atlantic Center
1201 West Peachtree Street
Atlanta, GA 30309-3424

404-881-7000
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


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.


cc:		John Bezzant, Executive Vice President Apartment Investment and Management Company Trent Johnson, Vice President and Assistant General Counsel Apartment Investment and Management Company