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Division of Corporate Finance

Securities and Exchange Commission

January 5, 2024

Page 1

January 5, 2024

Office of Mergers & Acquisitions

Division of Corporate Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attn: Blake Grady and Perry Hindin

 Re: Silver Star Properties REIT, Inc.

PREC14A filed December 22, 2023 by Allen Hartman et. al File No. 001-41786

DFAN14A filed December 22, 2023 by Allen Hartman et. al File No. 001-41786

DFAN14A filed December 22, 2023 by Allen Hartman et. al File No. 001-41786

Ladies and Gentlemen:

This letter is being submitted on behalf
of the filing persons of the above-referenced filings in response to the comments of the staff of the Division of Corporation Finance
(the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”), as set forth in your letter dated
January 3, 2024 (the “Comment Letter”).

In addition, we hereby submit for filing
via EDGAR a revised draft of the Preliminary Consent Revocation Statement on Schedule 14A filed December 22, 2023 (the “Consent
Revocation”), incorporating revisions requested by the Commission in the Comment Letter. The revised Consent Revocation submitted
herewith is referred to herein as the “Revised Consent Revocation”. Capitalized terms used herein but not otherwise defined
herein shall have the meanings set forth in the Revised Consent Revocation.

The text of the Comment Letter has been
reproduced herein, in bold, with our responses below each numbered comment.

Preliminary Consent Revocation Statement on Schedule
14A filed December 22, 2023 General

1. Please provide disclosure that is responsive to the requirements of Rule 14a-5(e). See Item 1(c) of
Schedule 14A.

Please see the revised disclosure
in the Revised Consent Revocation.

2. Advise us, with a view toward revised disclosure, whether or not the consent revocation card is
only valid for a specified number of days under the laws of the governing state jurisdiction.

Please see the revised disclosure
in the Revised Consent Revocation.

Division of Corporate Finance

Securities and Exchange Commission

January 5, 2024

Page 2

Background of the Consent Solicitation, page 4

3. We note your statement that “[o]n October 25, 2023, the Board adopted a second amendment to the Bylaws ... upon realizing that
the Executive Committee was prohibited by Maryland law from adopting bylaw amendments” (emphasis added). With a view towards
disclosure, please provide support for this statement.

Please see the revised disclosure in the
Revised Consent Revocation.

Questions and Answers About This Consent Revocation Statement,
page 6

4. Advise us, with a view toward revised disclosure, what consideration was given to describing the
option security holders have to revoke a previously submitted blue consent revocation card by submitting a later-dated white consent card.
Refer to Item 2 of Schedule 14A.

Please see the revised disclosure
in the Revised Consent Revocation.

5. Please revise this section to clarify the effect of marking “DO NOT REVOKE MY CONSENT”
on the blue consent revocation card. In this respect, if a shareholder has already submitted a white consent card, disclose whether there
is a risk that the execution of a subsequently dated blue consent revocation card could be counted as a revocation regardless of the box
selected.

Please see the revised disclosure
in the Revised Consent Revocation.

DFAN14A filed December 22, 2023

General

6. Refer to the following statements made in the bullet points within the letter to shareholders (emphasis
added):

 • Silver Star’s rogue Board of Directors has ignored my demands for a liquidation mandated
by the Company’s charter, and instead has named Haddock as the CEO of the Company and has awarded themselves Performance Units which
we expect to have a potentially significant value;

 • Their plans to reposition Silver Star as a self-storage company with their very limited self-storage
experience puts your money at risk and delays a return of your investment;

 • A vote for Silver Star’s consent solicitation would entrench the rogue directors as board
members and could block you from having a choice at an annual meeting;

 • As the largest shareholder, I have suffered losses of value due to their mismanagement. The
Company’s occupancy has declined precipitously since they fired me and took over;

 • After firing me, they hired two outside CEOs that have both turned over with no notice in
the last year; and

 • They are willing to say anything, regardless of its truth.

Division of Corporate Finance

Securities and Exchange Commission

January 5, 2024

Page 3

Each statement or assertion of opinion or belief
must be clearly characterized as such, and a reasonable factual basis must exist for such opinion or belief. Support for any such opinions
or beliefs should be self-evident, disclosed in the soliciting materials or provided to the staff on a supplemental basis with a view
toward disclosure. Please provide support for the foregoing and revise accordingly.

We propose to revise and re-file our
disclosure regarding the letter to shareholders in the form attached as Exhibit A hereto, upon receipt of the Commission’s
approval of our revisions. Please let us know if you have any further comments to such disclosure. In addition we have chosen to address
the last bullet point highlighted by the Commission directly below. Please see below the following examples of false or misleading statements
made by Silver Star, which we provide herein as a supplemental basis for the assertion that “They are willing to say anything, regardless
of its truth”:

 o In their Definitive Additional Materials filed with the Commission on January 5, 2024, Silver Star alleged, referring to me, that,
 “He was even using his inexperienced daughter, never having made a dime for any stockholder, to contact you and is still grooming
her to take over your company if he regains control.” This statement is not only unkind but false. My daughter has provided support
to me that is suitable to her experience level, and I am not and have never positioned her to be my successor at Silver Star.

 o In their Definitive Additional Materials filed with the Commission on December 29, 2023, Silver Star alleged that I caused a drop
in occupancy at our income-producing properties that triggered a drop in Silver Star’s NAV. This statement is false. Occupancy was
steady during my tenure, and was at 79% as of September 2022, the last month that I served as CEO; occupancy has now fallen under Gerald
Haddock’s leadership to 75%, based on Silver Star’s Quarterly Report for the third quarter of 2023.

 o In a press release dated November 29, 2023, Silver Star alleged that I was responsible for high executive turnover. This statement
is false. There was no executive turnover during my tenure. Dave Wheeler, CIO now Co-CEO, has a 20-year tenure at Silver Star.  Lou
Fox, former and current CFO, has a 15-year tenure. Kim Strickland, former COO, had a 10-year tenure and was terminated by Gerald Haddock.
The previous General Counsel, Mark Torok, had a 6-year tenure and was promoted to the position of CEO in 2022 but resigned after 6 months.
He subsequently left to start his own organization (which was later acquired by Silver Star Properties REIT). He was named CEO successor
to Al Hartman in 2022 again, and then fired by Gerald Haddock 3 months later.

DFAN14A filed December 22, 2023 General

7. Refer to the following statements made in the press release (emphasis added):

 • Hartman wishes to announce that the Hartman Group objects strongly to the re-
election of the incumbent directors, as well as the election process that they are running seemingly for their own benefit at the expense
of the stockholders;

Division of Corporate Finance

Securities and Exchange Commission

January 5, 2024

Page 4

 • The occupancy of the portfolio has plummeted under Mr. Haddock’s leadership
and assets are selling for depreciated prices; and

 • [O]ccupancy has dropped precipitously since Haddock took over 1 year ago.

Each statement or assertion of opinion or belief
must be clearly characterized as such, and a reasonable factual basis must exist for such opinion or belief. Support for any such opinions
or beliefs should be self-evident, disclosed in the soliciting materials or provided to the staff on a supplemental basis with a view
toward disclosure. Please provide support for the foregoing and revise accordingly.

We propose to revise and re-file our
disclosure regarding the press release in the form attached as Exhibit B hereto, upon receipt of the Commission’s approval
of our revisions. Please let us know if you have any further comments to such disclosure.

We hope the foregoing has been responsive to the
Staff’s comments and look forward to resolving any outstanding issues as quickly as possible. Please do not hesitate to contact
me at (212) 589-4233 with any questions or further comments you may have regarding this submission or if you wish to discuss the above.

    Sincerely,

    /s/ Adam W. Finerman

    Adam W. Finerman, Partner, Baker & Hostetler LLP

Exhibit A

Revised Disclosure Regarding Letter to Shareholders

[See attached]

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

SCHEDULE 14A INFORMATION

Proxy Statement Pursuant to Section 14(a) of

the Securities Exchange Act of 1934 (Amendment No.  )

Filed by the Registrant     ¨

Filed by a Party other than the Registrant     x

Check the appropriate box:

 ¨ Preliminary Proxy Statement

 ¨ Confidential,
                                            for Use of the Commission Only (as permitted by Rule 14a-6(e)(2))

 ¨ Definitive Proxy Statement

 ¨ Definitive Additional Materials

 x Soliciting Material under §240.14a-12

Silver Star Properties REIT, Inc.

(Name of Registrant as Specified in Its Charter)

Allen R. Hartman

 Hartman XX Holdings, Inc.

 Hartman vREIT XXI, Inc.

Hartman Family Protection Trust

LISA HARTMAN

Charlotte Hartman

VICTORIA HARTMAN MASSEY

MARGARET HARTMAN

(Name of Persons(s) Filing Proxy Statement, if Other Than the Registrant)

Payment of Filing Fee (Check all boxes that apply):

 x No fee required.

 ¨ Fee paid previously with preliminary materials.

 ¨ Fee computed on table in exhibit required by Item 25(b) per
Exchange Act Rules 14a-6(i)(1) and 0-11.

On December 22, 2023,The
below message is a revision of the message distributed by Allen Hartman and the other members of the Hartman Group distributed
the message below to the stockholders of Silver Star Properties REIT, Inc.:,
on December 22, 2023.

Subject Line: Your Silver Star Investment: Message from Allen Hartman

Silver Star Shareholder,

You may have received information from Silver Star regarding a consent
solicitation. We will be sending you a consent revocation statement. I strongly urge you to not vote in Silver Star’s consent solicitation,
for the following reasons:

 · Silver Star’s rogue Board of Directors has determined not to liquidate the
Company, but rather to embark upon a plan to obtain a listing on a national exchange “and satisfy the requirements of
the Company’s charter”, as per their Definitive Additional Materials filed with the SEC on December 29, 2023. I firmly believe
that it is too late to satisfy the applicable charter requirements at this time in the manner suggested by Silver Star, and that liquidating
Silver Star now is the only way to comply with the charter.

 · Instead of liquidating Silver Star’s
rogueStar, the Board of Directors has ignored
my demands for a liquidation mandated by the Company’s charter, and instead has named Haddock as the CEOCo-CEO
of the Company and, has awarded themselvesthe
members of the Executive Committee Performance Units which we expect to have a potentially significant value,
and has adopted the new self-storage strategy without first obtaining stockholder approval.

 · Their plans to reposition Silver Star as a self-storage
company with their very limited self-storage experience puts your money at risk and delays a return of your investment.

 · We firmly believe that the Board’s plans to reposition Silver Star as a self-storage company with puts your money at risk.
Any new strategy would come with inherent risk, but we are particularly concerned that the current leadership time may not have sufficient
experience in self-storage to execute the new strategy successfully. In any case, the current plan to implement the self-storage strategy
and pursue a stock exchange listing will delay what would otherwise, if Silver Star were liquidated, be a return of capital to you.

 · AWe
firmly believe that a vote for Silver Star’s consent solicitation would entrench the
rogue directorsfurther what we believe to be the Board’s goals of entrenching themselves
as board members and could block you from having a choice at an annual meeting.

 · As the largest shareholder, I fear that I have suffered losses
of value due to their mismanagement. The Company’s occupancy has declined precipitously since they
fired me and took over.that may have not been fully disclosed in Silver Star’s periodic
SEC reports, stemming from a decline in occupancy at our income-producing investment properties. Silver Star has historically disclosed
occupancy percentages with respect to income-producing properties owned by it and its subsidiaries; in its Quarterly Report on Form 10-Q
for the period ended September 30, 2022, for example, it reported occupancy percentages based on 44 properties. But Silver Star abruptly
switched its disclosure method in its Quarterly Report on Form 10-Q for the period ended September 30, 2023, so that the occupancy percentage
only pertains to the 3 properties directly owned by Silver Star. I can only speculate that the switch in disclosure was intentionally
motivated, perhaps to allow Silver Star to omit disclosure of lower occupancy at its properties owned by its subsidiaries. One thing is
certain, which is that in the Quarterly Report for the third quarter of 2023, the last report citing directly and indirectly owned properties,
Silver Star disclosed an occupancy percentage of 75%, which is the lowest occupancy percentage for the third quarter in the last 5 years
(and lower than even the occupancy percentage during the COVID-19 pandemic).

 · After firing me, they hired two outside CEOs that have both turned over with
no notice in the last year.

 · The Company’s independent auditor recently terminated their relationship with the Company.

 · TheyIn our view, they
are willing to say anything, regardless of its truth.

Is this who you want to be managing your hard-earned money, or do you
want it back? We will be sending our consent revocation statement. We urge you not to vote in Silver Star’s consent solicitation.

Please see the full story
in the attached and linked press release.

Should you have any questions, please contact our proxy solicitor at
the below contact information. With your help, we will regain control of this company, and return your capital to you.

Yours Truly,

Allen R Hartman

Former CEO, Director, and Largest Shareholder of Silver Star Properties
REIT, Inc.

Toll Free (877) 972-0090

info@investor-com.com

Additional Information

The
persons identified on the cover page hereto (collectively, the “Hartman Group”) have filed a Preliminary Consent Revocation
Statement (the “Preliminary Consent Revocation Statement”) together with a BLUE consent revocation card
with the SEC in connection with the consent solicitation initiated by Silver Star Properties REIT, Inc. (the “Consent Solicitation”),
and intends to file a Definitive Consent Revocation Statement (the “Definitive Consent Revocation Statement”) as soon as
possible. STOCKHOLDERS ARE URGED TO READ THE PRELIMINARY CONSENT REVOCATION STATEMENT (INCLUDING ANY AMENDMENTS OR SUPPLEMENTS THERETO),
THE DEFINITIVE CONSENT