NEW ENGLAND ZENITH FUND
NT-NSAR, 1999-02-23
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U.S. SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

FORM 12B-25	

SEC File Number	811-3728

CUSIP Numbers:
644264-20-2 SER. 1
644264-30-1 SER. 2
644264-10-3 SER. 3
644264-40-0 SER. 4
644264-50-9 SER. 5
644264-60-8 SER. 6
644264-70-7 SER. 7
644264-80-6 SER. 8
644264-88-9 SER. 9
644264-87-1 SER. 10
644264-86-3 SER. 11
644264-85-5 SER. 12
644264-84-8 SER. 13
644264-83-0 SER. 14

NOTIFICATION OF LATE FILING
(Check One):			  
[ ] Form 10-K  [ ] Form 11-K  [ ] Form 20-F  [ ] Form 10-Q [x] Form N-SAR
 
For Period Ended:  December 31, 1998

If the notification relates to a portion of the filing checked above, identify
the Item(s) to which the notification relates:

Part I -- Registrant Information

Full Name of Registrant:New England Zenith Fund

Former Name if Applicable
Address of Principal Executive Office (Street and Number)
399 Boylston Street
City, State and Zip Code
Boston, Mass. 02116

Part II - Rules 12b-25 (b) and (c)
If the subject report could not be filed without unreasonable effort or expense
and the registrant seeks relief pursuant to Rule 12b-25 (b), the following
should be completed.  [Check box if appropriate.]

[ ](a)The reasons described in reasonable detail in Part III of this form could
not be eliminated without unreasonable effort or expense:

[x](b)The subject annual report or semi-annual report/portion thereof will be
filed on or before the fifteenth calendar day following the prescribed due date;
or the subject quarterly report/portion thereof will be filed on or before the
fifth calendar day following the prescribed due date; and

[ ](c)The accountant's statement or other exhibit required by Rule 12b-25(c) has
been attached if applicable.

Part III -- Narrative

Our accounting staff (8) which prepares the Form(s) N-SAR is also currently
involved in the preparation of annual reports, semi-annual reports, and 
prospectuses. Accordingly, given the Form's reporting requirements, its early
file date and the total number of Funds and classes involved in the filings at
this time (83), the registrant wishes to assure that all items are answered
correctly and accurately. Therefore,the registrant requests relief pursuant to
Rule 12b-25(b).


Part IV -- Other Information

(1)Name and telephone number of person to contact in regard to this notification

Allison Troiani (617) 578-1693
(Name) (Area Code)Telephone Number

(2)Have all other periodic reports required under section 13 or 15(d) of the
Securities Exchange Act of 1934 or section 30 of the Investment Company Act of
1940 during the preceding 12 months or for such shorter period that the 
registrant was required to file such report(s) been filed?  If the answer is
no, identify report(s).

(3)Is it anticipated that any significant change in results of operations
from the corresponding period for the last fiscal year will be reflected by
the earnings statements to be included in the subject report or portion
thereof?

If so:  attach an explanation of the anticipated change, both narratively and
quantitatively, and, if appropriate, state then reasons why a reasonable
estimate of the results can not be made.

New England Zenith Fund
(Name of Registrant as specified in charter)
has caused this notification to be signed on its behalf by the under-signed
thereunto duly authorized.

Date:  2/23/99
By: /s/ Allison Troiani




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