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APARTMENT INVESTMENT AND MANAGEMENT COMPANY

4582 South Ulster Street Parkway, Suite 1100

Denver, Colorado 80237

April 15, 2009

Correspondence Filing Via Edgar

United States Securities and Exchange Commission

Division of Corporation Finance

Mail Stop 4561

450 Fifth Street, NW

Washington, D.C. 20549

    Attn:

    Cicely LaMothe

    Wilson K. Lee

    Re:

    Apartment Investment and Management Company

    File No. 001-13232

    Form 10-K for the year ended December 31, 2008

Ladies & Gentlemen:

     This letter responds to the comments of the staff of the Securities and Exchange Commission
(the “Staff”) addressed to Thomas M. Herzog on behalf of Apartment Investment and Management
Company (the “Company”), in a letter dated April 2, 2009. The Company’s response to the Staff’s
comments are set forth below and are numbered to correspond to the numbering of the Staff’s comment
in the Staff’s letter.

*     *     *     *     *

Financial Statements and Notes

Consolidated Statements of Income, page F-4

    1.

    Comment: 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.

Response: The Company’s consolidated statements of income include provisions for three types of
impairment losses: losses on notes receivable; impairment losses on operating real estate; and
impairment losses on real estate development assets.

United States Securities and Exchange Commission

April 15, 2009

Page 2 of 2

The Company includes losses on notes receivable below operating income to be consistent with the
presentation of interest income earned on notes receivable, which is included in non-operating
income in accordance with Rule 5-03 item 7 of Regulation S-X.

In assessing the classification of losses on real estate, the Company considered paragraph 25 of
SFAS 144 as well as the related basis for conclusions in paragraph B54, noting the FASB viewed
impairments as analogous to acceleration of depreciation or amortization related to long-lived
assets that would otherwise have been reflected in operating income over the remaining life or
holding period of the asset. The Company agrees with this conclusion related to impairments
recognized on assets anticipated to be held on a long-term basis, for which the impairment does
result in an acceleration of depreciation. However, the impairments recognized by the Company
resulted from operating real estate assets that are likely candidates for sale in the near term,
but that do not otherwise meet the SFAS 144 criteria to be classified as held for sale. Because
these assets are likely candidates for sale, the Company would not expect a corresponding amount of
depreciation to be recognized in its financial statements. The Company considers the impairments
more akin to recognizing a loss on the sale of the asset on an accelerated basis, which is a
different circumstance from the consideration provided in paragraph B54. Accordingly, the Company
believes the inclusion in operating income of such impairment losses would not be appropriate.

Real estate development assets include properties in the process of development that are neither
generating operating income nor subject to depreciation. As these development properties do not
affect operating income, the Company does not include related impairment losses in operating
income.

     As requested by the Staff, the Company acknowledges that: (a) the Company is responsible for
the adequacy and accuracy of the disclosure in its filings; (b) 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 (c) the Company may not assert Staff comments as a defense in any
proceeding initiated by the Commission or any person under the federal securities laws of the
United States.

     If you have further questions regarding the information provided, please contact Paul Beldin,
Senior Vice President and Chief Accounting Officer, at (303) 691-4554 (phone) or (720) 493-6549
(facsimile), or me at (303) 691-4311 (phone) or (303) 300-3276 (facsimile). In addition, in the
event of additional correspondence on this matter or correspondence on any future matter from the
Staff, please include Mr. Beldin as an addressee.

    Sincerely,

/s/ David Robertson

David Robertson

President, Chief Investment Officer and Chief

Financial Officer

    Cc:

    Lisa R. Cohn

    Paul Beldin