May 5, 2005

By Facsimile and U.S. Mail

Joseph A. Coco
Skadden, Arps, Slate, Meagher & Flom LLP
Four Times Square
New York, New York 10036

Jonathan L. Friedman
Jonathan Ko
Skadden, Arps, Slate, Meagher & Flom LLP
300 South Grand Avenue
Los Angeles, California 90071

Re:	National Property Investors III, Fox Strategic Housing
	Income Properties
      Century Properties Fund XIV, XV, XIX, and XXII, Davidson
	Income Real Estate LP, and Davidson Growth Plus LP
      Amended Schedule TO-T/13E-3s
      Filed April 27, 2005 by AIMCO Properties LP, et al.

Dear Messrs. Coco, Friedman and Ko:

	We have the following comments on the above-referenced
filings. Please note that the page numbers indicated below correspond
to the disclosure in the Offer to Purchase units of National Property
Investors III, except as otherwise noted.  Please make
corresponding changes, where applicable, to each of the above-referenced
filings in response to these comments.

1. We note your response to comment 2.  Rule 14d-4(d)(1) and Rule
13e-3(f)(1)(iii) require you to promptly disseminate notice of any
material changes to your offers to security holders.  Please
provide us with your analysis of your compliance with these Rules.
We note that you have amended the Schedules and, in some cases, you
have issued press releases with respect to changes; however, it does
not appear that you have mailed revised information.

2. We note that the Court of Appeals vacated the trial court`s
approval of the Nuanes and Heller litigation settlement.  Please
further explain, on a supplemental basis, the significance of this
ruling and status of those cases and the settlement fund, with a
view toward clarified disclosure.  We note that several of your prior
offers were conducted pursuant to the agreements of settlement.

3. We note that you will file the appraisals obtained in connection
with refinancing properties held in the CPF XIX and DIRE tender offers.
Also revise your Item 1014 analysis in light of this information.
In addition, tell us whether the appraisals were completed at the
time of any prior offers you conducted for units of these partnerships.
If so, provide us your analysis of AIMCO`s compliance with the
disclosure requirements of Items 1014 and 1015 of Regulation M-A
in connection with its Schedule 13E-3 filings.

4. We reissue comment 10.  We note the increased offer prices in
the competed offers.  It appears the filing persons should revise
their Schedule 13E3, and in particular the analysis required by Item
1014 to reflect the competing offers.  See Instruction 2(i) to Item
1014(b).  In addition, tell us when AIMCO learned of the mini-
tender offers discussed in your supplemental response and how AIMCO
became aware of the mini-tender offers.  Clarify AIMCO`s compliance
with the disclosure requirements of Item 1014(b) of Regulation M-A,
and in particular, Instruction 2(i) to Item 1014(b) with respect to
the mini tender offers.

      Please respond to these comments by promptly amending the
filing and submitting a response letter filed via EDGAR under the
label "CORRESP."  If the information you provide in response to
our comments materially changes the information that you have already
provided to security holders, disseminate the revised materials in
a manner reasonably calculated to inform them of the new
information. If you do not agree with a comment, please tell us why in
your response.  Direct any questions to me at (202) 551-3262.  You may
also contact me by facsimile at (202) 772-9203.

Sincerely,



Abby Adams
Special Counsel
Office of Mergers and Acquisitions