SPARTA The Source for Powersports Financing
COMMERCIAL SERVICES www.spartacommercial.com
January 6, 2006
VIA FAX AND EDGAR
Ms. Margaret Fitzgerald Division of Corporate Finance U.S. Securities & Exchange
Commission Washington, D.C. 20549
Re: Sparta Commercial Services, Inc.
Form 10-KSB for Fiscal Year Ended April 30, 2005
Filed July 25, 2005
File No. 000-09483
Dear Ms. Fitzgerald :
This will acknowledge receipt of the letter of comment dated December 21, 2005
with regard to the above referenced filing. Our response, which reference your
comment number, follow.
Results of Operations
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Comparison of the Year Ended April 30, 2005 to the Year Ended April 30, 2004
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Net Loss, page 18
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Comment 1 - Response:
We have amended our Form 10-KSB, which has been filed via Edgar, to present the
payment for the option as a separate line item on the consolidated statement of
losses. In subsequent filings, we will also present the payment for the option
as a separate line item on the consolidated statement of losses, and we will
provide the requested disclosures in future filings.
Comment 2 - Response
We have filed via Edgar the paper correspondence which was submitted via fax on
December 14, 2005 and December 19, 2005.
We thank you for your assistance in this matter. If you have any questions or
additional comments, please do not hesitate to contact me at 212.239.2666.
Yours truly,
SPARTA COMMERCIAL SERVICES, INC.
/s/ A. L. Havens
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Anthony L. Havens, President
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P.O. Box 60 New York, NY 10156 Tel: (800) 882-0778 Fax: (212) 239-2799
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