Mail Stop 4561
								November 30, 2005

By U.S. Mail and Facsimile to (212) 239-2799

Anthony L. Havens
Chief Executive Officer and Principal Financial Officer
Sparta Commercial Services, Inc.
462 Seventh Avenue, 20th Floor
New York, New York 10018

Re:	Sparta Commercial Services, Inc.
	Form 10-KSB for Fiscal Year Ended April 30, 2005
      Filed July 25, 2005
	File No. 000-09483

Dear Mr. Havens:

      We have reviewed your response filed on November 15, 2005
and
have the following additional comment.  If you disagree, we will
consider your explanation as to why our comment is inapplicable or
a
revision is unnecessary.  After reviewing this information, we may
raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comment or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Results of Operations
Comparison of the Year Ended April 30, 2005 to the Year Ended
April
30, 2004
Net Loss, page 18
1. We note your response to our comment letter dated November 4,
2005.  The terms of the purchase option noted in your response
indicate that the characterization of this arrangement as an
option
may be inappropriate, given the restrictions on the purchases and
the
fact that payments are being made to your majority shareholder.
Please tell us, and revise your filings to include the underlying
business purpose of this option.


       Please respond to this comment letter within 10 business
days
or tell us when you will provide us with a response.  Please
furnish
a cover letter with your response indicating your intent to
provide
the requested disclosures in future filings.  Please provide us
drafts of your proposed revisions, where applicable, and any
requested information.  Detailed cover letters greatly facilitate
our
review.  Please understand that we may have additional comments
after
reviewing your response to our comment.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.

	You may contact Margaret Fitzgerald at (202) 551-3556 or me
at
(202) 551-3490 if you have questions regarding comments on the
financial statements and related matters.


      Sincerely,



      Don Walker
Senior Assistant Chief Accountant


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Anthony L. Havens
Sparta Commercial Services, Inc.
November 30, 2005
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