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     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.: 333-175847

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. 333-175847) on Form S-4 (the “NPI 4 Form S-4”) referenced above. The NPI 4 Form S-4 relates to the merger of National Property Investors 4.

          We hereby confirm, on behalf of Aimco and Aimco OP, that the changes made to the NPI 4 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 NPI 4 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 Robert Mintz at (303) 899-7399.

Mr. Adem F. Trunk
Securities and Exchange Commission
December 19,2011
Page 2

Respectfully yours,

/s/ Robert Mintz

Robert Mintz

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