APARTMENT INVESTMENT AND MANAGEMENT COMPANY
AIMCO PROPERTIES, L.P.
4582 South Ulster Street Parkway, Suite 1100
Denver, Colorado 80237
January 15, 2010
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 | ||
AIMCO Properties, L.P. File No. 000-24497 Form 10-K for the year ended December 31, 2008 |
Ladies & Gentlemen:
This letter responds to the comment of the staff of the Securities and Exchange Commission (the “Staff”) addressed to Paul Beldin on behalf of Apartment Investment and Management Company (“Aimco”) and AIMCO Properties, L.P., a Delaware limited partnership (collectively, the “Companies”), in a letter dated January 4, 2010. The Companies’ response to the Staff’s comment is set forth below.
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United States Securities and Exchange Commission
January 15, 2010
Page 2 of 2
Form 10-K for the year ended December 31, 2008
Financial Statements and Notes
Consolidated Statements of Income, page F-4
1. | Comment: As it relates to your proposal to present the impairment losses within operating income in future filings, please supplementally confirm that in your 10-K for the fiscal year ended December 31, 2009, you will ensure all impacted financial statement columns are labeled as restated and you will provide all the required disclosures outlined in paragraph 250-10-50-7 of the FASB Accounting Standards Codification. |
Response: In response to the Staff’s comment, the Companies confirm that in their Forms 10-K for the year ended December 31, 2009, they will ensure all affected financial statement columns are labeled as restated and they will provide the required disclosures outlined in paragraph 250-10-50-7 of the FASB Accounting Standards Codification.
If you have further questions regarding the information provided, please contact Ernie Freedman, Executive Vice President and Chief Financial Officer, at (303) 691-4316 (phone) or (720) 493-6545 (facsimile) or me at (303) 691-4554 (phone) or (720) 493-6549 (facsimile).
Sincerely,
/s/ Paul Beldin
Paul Beldin
Chief Accounting Officer of Aimco and AIMCO-GP, Inc.,
the general partner of AIMCO Properties, L.P.
Cc: | Amy B. Freed, Hogan & Hartson LLP Lisa R. Cohn, Aimco Ernie Freedman, Aimco |
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