IRE REAL ESTATE GROWTH FUND LTD SERIES 28
15-12G, 1995-04-12
REAL ESTATE
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                       SECURITIES AND EXCHANGE COMMISSION
                            Washington, D.C.  20549

                                    FORM 15

Certification and Notice of Termination of Registration under Section 12(g) of
the Securities Exchange Act of 1934 or Suspension of Duty to File Reports Under
Sections 13 and 15(d) of the Securities Exchange Act of 1934.

                                                 Commission File Number
                                                          0-13877
                                                   --------------------


                I.R.E. REAL ESTATE GROWTH FUND, LTD. - SERIES 28
                     (Exact Name of Registrant as Specified
                   in its Certificate of Limited Partnership)

1750 East Sunrise Boulevard - Third Floor
Fort Lauderdale, Florida 33304
(305) 760-5200
- ---------------------------------------------------

Address and telephone of Principal Executive Office


Securities registered pursuant to Section 12(b) of the Act:  None

Securities registered pursuant to Section 12(g) of the Act:

                           Limited Partnership Units
                    $500 Per Unit - Minimum Purchase 6 Units
                  4 Units for an Individual Retirement Account

Title of all other classes of securities for which a duty to file reports under
Section 13(a) or 15(d) remains:  None

Please place an X in the box(es) to designate the appropriate rule provision(s)
relied upon to terminate or suspend the duty to file reports:

      Rule 12g-4(a)(1)(i)      [x]        Rule 12h-3(b)(1)(ii)       [ ]
      Rule 12g-4(a)(1)(ii)     [ ]        Rule 12h-3(b)(2)(i)        [ ]
      Rule 12g-4(a)(2)(i)      [ ]        Rule 12h-3(b)(2)(ii)       [ ]
      Rule 12g-4(a)(2)(ii)     [ ]        Rule 15d-6                 [ ]
      Rule 12h-3(b)(1)(i)      [x]

Approximate number of holders of record as of the certification or notice date:
    0
 ------


Pursuant to the requirements of the Securities Exchange Act of 1934, the
Registrant has caused this certification /notice to be signed on its behalf by
the undersigned duly authorized person.

                    I.R.E. REAL ESTATE GROWTH FUND, LTD. - SERIES 28
                    -------------------------------------------------

                                   Registrant
                    By:  I.R.E. Advisors Series 28, Corp.,
                         Managing General Partner
March 31, 1995
                    By:  /s/ Glen R. Gilbert
                         -------------------------------------
                         Glen R. Gilbert, Senior Vice President
                         



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