ADHIA FUNDS INC
24F-2NT, 2000-02-15
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

FORM 24F-2
Annual Notice of Securities Sold
Pursuant to Rule 24f-2

Read instructions at end of Form before preparing Form.

1.        Name and address of issuer:

Adhia Funds, Inc,  1311 N. Westshore Blvd., Suite 110, Tampa, FL 33607


2.        Name of each series or class of securities for which this Form is
          filed (If the Form is being  filed for all series and  classes of
          securities of the issuer, check the box but do not list series or
          classes): [X]


3.        Investment Company Act File Number:     811-08755

          Securities Act File Number:   333-52381


4(a).     Last day of fiscal year for which this Form is filed: 12/31/1999


4(b).     Check box if this Form is being  filed late  (i.e.,  more than 90
          calendar days after the end of the issuer's  fiscal  year).  (See
          Instruction A.2)

Note:  If the  Form  is  being  filed  late,  interest  must be paid on the
registration fee due.


4(c).   Check box if this is the last time the issuer will be filing this
        Form.


5.        Calculation of registration fee:

          (i)  Aggregate    sale   price   of           |               |
               securities   sold  during  the           |               |
               fiscal   year    pursuant   to           |   $ 287.861   |
               section 24(f):                           |               |

          (ii) Aggregate  price of securities           |               |
               redeemed or repurchased during   	|     -0- 	|
               the fiscal year:                         |               |

          (iii)Aggregate  price of securities           |               |
               redeemed or repurchased during           |               |
               any prior  fiscal  year ending           |       	|
               no earlier  than  January 1,             |               |
               1999 that were not  previously           |      -0-      |
               used  to  reduce  registration           |               |
               fees     payable     to    the           |               |
               Commission:                              |               |

          (iv) Total   available   redemption           |               |
               credits  [add Items  5(ii) and           |      -0-      |
               5(iii)]:                                 |               |

          (v)  Net  sales - if  Item  5(i) is 		|        	|
               greater    than   Item   5(iv) 		|         	|
               [subtract Item 5(iv) from Item           |     $ 287,861 |
               5(i)]:                                   |               |

          (vi) Redemption  credits  available           |               |
               for use in  future  years - if 		|        	|
               Item  5(i) is less  than  Item           |      -0-      |
               5(iv)   [subtract  Item  5(iv)           |               |
               from Item 5(i)]:               		|        	|


          (vii)Multiplier   for   determining           |               |
               registration fee                         | x .000264     |
               (See Instruction C.9):                   |               |

          (viii)Registration      fee     due           |               |
               [multiply  Item  5(v)  by Item           |               |
               5(vii)]  (enter  "0" if no fee           |    $ 80.03    |
                              is due):                  |               |

6.        Prepaid Shares       					N/A

          If the  response  to Item 5(i) was  determined  by  deducting  an
          amount of securities  that were  registered  under the Securities
          Act of 1933  pursuant to rule 24e-2 as in effect  before  October
          11, 1997, then report the amount of securities  (number of shares
          or other units)  deducted  here:  _______________.  If there is a
          number of shares or other units that were registered  pursuant to
          rule 24e-2  remaining  unsold at the end of the  fiscal  year for
          which this form is filed that are available for use by the issuer
          in  future   fiscal   years,   then  state  that   number   here:
          __________________


7.        Interest  due - if this  Form is being  filed  more  than 90 days
          after the end of the issuer's fiscal year (see Instruction D):

                                                                + $  -0-


8.        Total of the amount of the registration fee due plus any interest
          due [line 5(viii) plus line 7]:

                                                                = $ 80.03


9.        Date the  registration  fee and any interest  payment was sent to
          the Commission's lockbox depository:

               Method of Delivery:      N/A

                    [X]       Wire Transfer

                    [ ]       Mail or other means


SIGNATURES

This report has been signed below by the following persons on behalf of the
issuer and in the capacities and on the dates indicated.

By (Signature and Title)*     /s/ Hitesh P. Adhia
                              -----------------------------------------------
                              Hitesh P. Adhia, Vice President of Compliance
                              -----------------------------------------------
Date      2/10/2000
     	-----------------

*Please print the name and title of the signing officer below the signature.





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