Mail Stop 4561
								December 21, 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 submitted via fax on December
14, 2005 and have the following additional comments.  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 submitted via fax
on
December 14, 2005, and we have reviewed the terms of the Option to
Purchase Agreement submitted via fax on December 19, 2005.  Please
amend your Form 10-KSB and subsequent filings to present the
payment
for the option as a separate line item on your consolidated
statement
of losses.  Please label this line item as "Payment for option to
purchase portfolio from a related party."

2. Please file via EDGAR the paper correspondence which was
submitted
via fax on December 14, 2005 and December 19, 2005.


      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.
December 21, 2005
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