LETTER 1 filename1.txt Mail Stop 4561 January 23, 2006 By U.S. Mail 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 the Fiscal Year Ended April 30, 2005 File No. 000-09483 Dear Mr. Havens: We have completed our review of your Form 10-KSB and related filings and have no further comments at this time. Sincerely, Don Walker Senior Assistant Chief Accountant