SecProbe.io

Mail Stop 4561

     April 2, 2009

 VIA USMAIL and FAX (303) 759 - 3226   Mr. Thomas M. Herzog Vice President and Chief Financial Officer Apartment Investment & Management Company 4582 South Ulster Street Parkway, Suite 1100 Denver, Colorado 80237
Re: Apartment Investment & Management Company
  Form 10-K for the year ended 12/31/2008
Filed 2/27/2009 File Nos. 001-13232
 Dear Mr. Thomas M. Herzog:
We have reviewed your filing and have the following comment.  We have limited
our review to only the issues addressed below and will make no further review of your
document.  As such, all persons who are responsible for the adequacy and accuracy of the disclosure are urged to be certain that they have included all information required
pursuant to the Securities Exchange Act of 1934.
 Where indicated, we think you should revise  your document in response to this
comment.  If you disagree, we will consider your explanation as to why our comment is
inapplicable or a revision is unnecessary.  Pl ease be as detailed as necessary in your
explanation.  In our comment, we may ask you to provide us with information so we may
better understand your disclosure.  After review ing this information, we may or may not
raise additional comments.   Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosures in your filing.  We look forward to working with you in these respects.  We
welcome any questions you may have about our comment or on any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Thomas M. Herzog
Apartment Investment & Management Company
April 2, 2009 Page 2  FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2008

 Financial Statements and Notes

 Consolidated Statements of Income, page F-4

1. Reference is made to the presentation  of your provision for impairment losses
below operating income.  Please advise us  of your consideration of paragraph 25
of SFAS 144.  In addition, please clarify your basis for including losses on notes
receivable below operating income.

*    *    *    *

As appropriate, please respond to this comm ent within 10 business days or tell us
when you will provide us with a response.  Please submit a response letter on EDGAR that keys your response to our comment and provides any requested information.
Detailed response letters great ly facilitate our review.  Please understand that we may
have additional comments after revi ewing your response to our comment.
  We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filings reviewed by the staff to be certain that they have provided all
information investors require for an info rmed decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
  In connection with responding to our comment, please provide, in writing, a statement from the company acknowledging that
• the company is responsible for the adequacy  and accuracy of the disclosure in the
filings;

• staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filings; and

• the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filings or in response to our comments on your filings.

Thomas M. Herzog
Apartment Investment & Management Company April 2, 2009 Page 3   You may contact Wilson K. Lee, at (202) 551-3468 or me, at (202) 551-3413 if
you have questions.                Sincerely,
     Cicely LaMothe      Branch Chief