Exhibit 12

Kirkpatrick & Lockhart llp
1800 Massachusetts avenue, n.w.
2nd floor
washington, d.c.  20036-1800
telephone (202) 778-9000
facsimile (202) 778-9100

October 27, 1999

Fidelity Select Portfolios
82 Devonshire Street
Boston, MA  02109

Ladies and Gentlemen:

 Fidelity Select Portfolios ("FSP"), a Massachusetts business trust,
on behalf of Fidelity Select Precious Metals and Minerals Portfolio
("Acquired") and Fidelity Select Gold Portfolio ("Acquiring"), both
series of FSP, has requested our opinion as to certain federal income
tax consequences of a transaction ("Reorganization") in which
Acquiring will acquire all of the assets and assume all of the
liabilities of Acquired in exchange solely for shares of beneficial
interest in Acquiring ("Acquiring Shares") pursuant to an Agreement
and Plan of Reorganization ("Agreement") expected to be entered into
between Acquired and Acquiring as of December 20, 1999.

 In rendering this opinion, we have examined a draft of the Agreement
("Draft Agreement"), the prospectus/proxy statement to be filed with
the Securities and Exchange Commission in connection with the
Reorganization, the currently effective prospectuses and statements of
additional information of Acquired and Acquiring, and such other
documents as we have deemed necessary.  We have also relied, with your
consent, on certificates of officers of FSP.

 OPINION

 Based solely on the facts and representations set forth in the
reviewed documents and the certificates of officers of FSP, and
assuming that (i) those representations are true on the date of the
Reorganization, (ii) the Reorganization is consummated in accordance
with the Agreement, and (iii) the Agreement does not differ materially
from the Draft Agreement, our opinion with respect to the federal
income tax consequences of the Reorganization is as follows:

 1. The Reorganization will be a reorganization under Section
368(a)(1)(C) of the Internal Revenue Code of 1986, as amended
("Code"), and Acquired and Acquiring will each be parties to the
Reorganization under Section 368(b) of the Code.

 2. No gain or loss will be recognized by Acquired upon the transfer
of all of its assets to Acquiring in exchange solely for Acquiring
Shares and Acquiring's assumption of Acquired's liabilities followed
by the distribution of those Acquiring Shares to the Acquired
shareholders in liquidation of Acquired.

 3. No gain or loss will be recognized by Acquiring on the receipt of
Acquired's assets in exchange solely for Acquiring Shares and the
assumption of Acquired's liabilities.

 4. The basis of Acquired's assets in the hands of Acquiring will be
the same as the basis of such assets in Acquired's hands immediately
prior to the Reorganization.

 5. Acquiring's holding period in the assets to be received from
Acquired will include Acquired's holding period in such assets.

 6. The Acquired shareholders will recognize no gain or loss on the
exchange of shares of beneficial interest in Acquired ("Acquired
Shares") solely for the Acquiring Shares in the Reorganization.

 7. The Acquired shareholders' basis in the Acquiring Shares to be
received by them will be the same as their basis in the Acquired
Shares to be surrendered in exchange therefor.

 8. The holding period of the Acquiring Shares to be received by the
Acquired shareholders will include the holding period of the Acquired
Shares to be surrendered in exchange therefor, provided those Acquired
Shares were held as capital assets on the date of the Reorganization.

 The foregoing opinion is based on, and is conditioned on the
continued applicability of, the provisions of the Code and the
regulations thereunder, case law precedent, and the Internal Revenue
Service pronouncements in existence at the date hereof.  We express no
opinion as to whether Acquired will recognize gain or loss in the
Reorganization under Section 1256 of the Code with respect to futures,
forwards, or options, or income or deductions under Section 1296 of
the Code with respect to its investments in passive foreign investment
companies.  Nor do we express any opinion other than those contained
herein.

 We consent to the inclusion of this opinion in the Registration
Statement on Form N-14 filed with the Securities and Exchange
Commission and the inclusion of the name "Kirkpatrick & Lockhart LLP"
in the "Federal Income Tax Consequences of the Reorganization,"
"Federal Income Tax Considerations" and "Legal Matters" Sections of
that Registration Statement.

      Very truly yours,

      /s/ Kirkpatrick & Lockhart LLP
          Kirkpatrick & Lockhart LLP