BULL & BEAR SPECIAL EQUITIES FUND INC
497J, 1997-05-22
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                                                  Bull & Bear Advisers, Inc.
                                                  11 Hanover Square
                                                  New York, NY 10005


May 22, 1997

Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549

VIA EDGAR

        Re:      Bull & Bear Special Equities Fund, Inc. -- File No. 33-2847
                 Rule 497(j) Certification

Dear Sir or Madam:

         Pursuant to section (j) of Rule 497 under the  Securities  Act of 1933,
as amended,  Bull & Bear  Special  Equities  Fund,  Inc.  ("Registrant")  hereby
certifies:

1.   The form of prospectus  and Statement of  Additional  Information  that
     would have been filed under  paragraph (b) or (c) of Rule 497 would not
     have differed  from that  contained in the  Registrant's  most recently
     filed registration statement; and

2.   The text of the Registrant's most recent registration statement has been 
     filed electronically.

         Should you have any  questions or require any  additional  information,
please do not hesitate to contact me directly at (212)  785-0900,  extension 208
or Thomas B. Winmill at extension 222. Thank you very much.

                                                 Very truly yours,

                                            BULL & BEAR ADVISERS, INC.


                                              By: William J. Maynard
                                                  Vice President


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