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Document Preview Opinion Letter Re: United States Federal Income Tax Consequences |
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Title: |
Opinion Letter Re: United States Federal Income Tax Consequences |
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Entities: |
Aimco Properties, LP; Apartment Investment & Management Co.; Akin, Gump, Strauss, Hauer & Feld LLP; Altheimer & Gray; Skadden, Arps, Slate, Meagher & Flom LLP; AIMCO Operating Partnership |
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Date: |
2002 |
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Size: |
Preview shows 2KB of 14KB total |
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Price: |
$38 |
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ID: |
#265416 |
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[LETTERHEAD OF SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP]
August 15, 2002
AIMCO Properties, L.P.
Colorado Center, Tower Two
2000 South Colorado Boulevard, Suite 2-1000
Denver, Colorado 80222
Re: United States Federal Income Tax Consequences
Ladies and Gentlemen:
You have requested our opinion concerning certain United
States Federal income tax considerations in connection with the offer (the
"Offer") by AIMCO Properties, L.P., a Delaware limited partnership (the "AIMCO
Operating Partnership"), to acquire up to an aggregate of 270 units of limited
partnership interests of VMS National Residential Portfolio I ("VMS") from
owners of such partnership units (an "Offeree") in exchange for (i) $3,000 cash,
(ii) 64.50 AIMCO Operating Partnership Common Units ("Common OP Units"), or
(iii) a combination of cash and Common OP Units, as more fully described in the
Registration Statement on Form S-4 (No. 333-90590) of the AIMCO Operating
Partnership, initially filed with the Securities and Exchange Commission (the
"Commission") on June 17, 2002 under the Securities Act of 1933, as amended (the
"Securities Act"), as such Registration Statement is amended through the date
hereof. All capitalized terms used herein, unless otherwise specified, shall
have the meanings assigned to them in the Registration Statement.
In connection with the Offer and with certain previous
offerings of Common OP Units, we have acted as special tax counsel to the AIMCO
Operating Partnership, and we have assisted in the preparation of the
Registration Statement and certain other documents. In formulating our opinion,
we have examined originals or copies, certified or otherwise identified to our
satisfaction, of the Registration Statement
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