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[SASM&F Letterhead]

October 14, 2010

VIA EDGAR

Tom Kluck, Branch Chief

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

Registration Statement on Form S-4

Filed September 14, 2010

File No. 333-169353

Gentlemen:

          On behalf of Apartment Investment and Management Company, a Maryland corporation (the
“Company” or “Aimco”), we are submitting this letter in response to your letter to John Bezzant,
dated October 5, 2010, regarding the Company’s Registration Statement on Form S-4, file No.
333-169353, filed with the Securities and Exchange Commission (the “Commission”) on September 14,
2010 (the “Form S-4”).

          For your convenience, your comments are set forth below, followed by the Company’s responses.
References to page numbers correspond to the page numbers in the Form S-4.

    1.

    We note your disclosure on page 94 regarding the incorporation by reference of Aimco OP’s
periodic reports. Please provide us with an analysis detailing your eligibility to
incorporate by reference the filings of Aimco OP in this Form S-4.

    Response:

          Under General Instruction I.B. to Form S-4, a registrant that “meets the requirements for use
of Form S-3” may elect to furnish certain information about the registrant by incorporating such
information by reference into a prospectus pursuant to Items 10 and 11 of Form S-4. In order to
“meet the requirements for use of Form S-3,” General Instruction I.B.a.A. to Form S-4 provides that
a registrant must (i) meet the registrant requirements described in

October 14, 2010

Page 2

General Instruction I.A. of Form S-3 (the “Registrant Requirements”), and (ii) meet the
aggregate market value transaction requirements described in General Instruction I.B.1 of Form S-3
(the “Aggregate Market Value Transaction Requirements”).

     Registrant Requirements

          Aimco Properties, L.P. (“Aimco OP”) satisfies the Registrant Requirements of General
Instruction I.A.:

    •

    Aimco OP is a Delaware limited partnership with its principal business operations in
the United States.

    •

    Aimco OP’s partnership common units are registered pursuant to Section 12(g) of the
Securities Exchange Act of 1934 (the “Exchange Act”).

    •

    Aimco OP has been subject to the requirements of Section 12 of the Exchange Act and
has filed in a timely manner all material required to be filed pursuant to Section 13,
14 or 15(d) of the Exchange Act for and during the 12 calendar months (and the portion
of the month) immediately preceding the filing of the Form S-4.

    •

    Since December 31, 2009, Aimco OP has not failed to pay dividends on its various
classes of preferred partnership units, and has not defaulted on any indebtedness or
any rental on one or more long term leases, which defaults in the aggregate would be
material to Aimco OP’s and it subsidiaries’ financial position, taken as a whole.

    •

    Aimco OP has filed with the Commission all required electronic filings. As an
accelerated filer, under Regulation S-K 601(b)(101)(i)(C), Aimco OP is not required to
submit Interactive Data Files pursuant to Rule 405 of Regulation S-T in applicable
public filings until such filings contain financial statements for a fiscal period that
ends on or after June 15, 2011.

     Aggregate Market Value Transaction Requirements

          Aimco OP also satisfies the Aggregate Market Value Transaction Requirements:

    •

    The aggregate market value of the voting and non-voting common equity held by
non-affiliates of Aimco OP exceeds $75 million. Although there is no public market for
Aimco OP limited partnership units, after a one-year holding period, each Aimco OP
limited partnership unit (an “OP Unit”) is generally redeemable for cash in an amount
equal to the value of one share of Aimco’s common stock at the time, subject to Aimco’s
right to acquire each OP Unit in exchange for one share of Aimco common stock (subject
to antidilution adjustments). The Aimco common stock is traded on the NYSE under the
symbol “AIV.” Therefore, the trading price of Aimco common stock is considered a
reasonable proxy for the fair market value of an OP Unit. The average of the bid and
asked prices of Aimco common stock on September 7, 2010 was $21.66. As reported in
Aimco OP’s Quarterly Report for the period ended June 30, 2010, as of July 28, 2010,
there were 123,021,611 OP Units outstanding, and at least 5,125,940 of those OP Units
were held by non-affiliates, so the aggregate market value of the common equity of
Aimco OP held by non-affiliates

October 14, 2010

Page 3

based on the average of the bid and asked prices of Aimco common stock on September 7,
2010 was at least $111 million.

     Conclusion

          Because Aimco OP “meets the requirements for use of Form S-3” pursuant to General Instruction
I.B. to Form S-4, it may elect to furnish certain information by incorporating such information by
reference into the prospectus pursuant to Items 10 and 11 of Form S-4.

    2.

    We note that on page 94 of your registration statement on Form S-4, you did not properly
incorporate future filings prior to the effective date of your registration statement. See
Compliance and Disclosure Interpretations, Securities Act Forms, Question 123.05. Therefore,
please amend your registration statement, as necessary, to specifically incorporate by
reference any quarterly reports or applicable current reports that are filed after your
initial registration statement and prior to effectiveness.

    Response:

          The Company will amend the second paragraph on page 94 of the registration statement on Form
S-4 to read as follows:

          “The information that Aimco and Aimco OP file with the SEC is incorporated by reference, which
means that important information is being disclosed to you by referring you to those documents. The
information incorporated by reference is considered to be part of this information
statement/prospectus. The documents listed below are incorporated by reference along with all
documents filed by us with the SEC pursuant to Section 13(a), 13(c), 14 or 15(d) of the Exchange
Act (i) after the date of the initial registration statement and prior to effectiveness of the
registration statement and (ii) after the date of this prospectus and before the completion of the
offering of the shares described in this prospectus.”

    3.

    Please amend your registration statement to provide undertakings required by Item 512(a)(5)
and (6) of Regulation S-K.

    Response:

     The Company will amend “Part II—Item 22. Undertakings” to include the undertakings
requires by Item 512(a)(5) and (6) of Regulation S-K.

October 14, 2010

Page 4

          If you have any questions regarding the foregoing, please contact Jonathan Friedman at (213)
687-5396 or the undersigned at (213) 687-5618.

    Respectfully yours,

    /s/ Michael Moulton

    cc:

    Derek McCandless

John Bezzant