SecProbe.io

April 24, 2012
                                                                                                  Via E-Mail

Ernest M. Freedman Chief Financial Officer Apartment Investment and Management Company  4582 South Ulster Street Parkway, Suite 1100 Denver, CO  80237
                 Re: Apartment Investment and Management Company
Form 10-K for the Fiscal Year Ended December 31, 2011 Filed February 23, 2012 File No. 001-13232

Dear Mr. Freedman:

We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us w ith information so we may better understand
your disclosure.
 Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested response.  If you do not believe  our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.

Form 10-K for the Fiscal Year Ended December 31, 2011 filed February 23, 2012

 Investing Activities, page 35

 1. We note your response to comment two and three in our letter dated March 16, 2012.
It appears from your response to comment th ree that capital expenditures presented
within the statements of cash flows as investment activities include capital
replacements . Please explain to us your basis fo r capitalizing these costs given your
response to comment two that capital replacements do not enhance the value,
profitability, or useful life of an asset as compared to its condition at the time you
purchased the asset.

Ernest M. Freedman
Apartment Investment and Management Company
April 23, 2012 Page 2

 We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes the information the Securities
Exchange Act of 1934 and all applicable Exch ange Act rules require.  Since the company
and its management are in possession of all f acts relating to a company’s disclosure, they
are responsible for the accuracy and adequacy  of the disclosures they have made.

 In responding to our comments, please provide a written statement from the
company acknowledging that:
 the company is responsible for the adequacy  and accuracy of the disclosure in the
filing;

 staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; 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.
 If you have any questions, you may contact  Jorge L. Bonilla at (202) 551-3414 or
me at (202) 551-3486.

                                                                                     Sincerely,
        /s/ Daniel L. Gordon

Daniel L. Gordon
                                                                                    Branch Chief