A semiconductor memory device and a method of fabricating the same which is suitable for fabrication of a non-volatile memory, such as an EEPROM, using a polysilicon-insulator-polysilicon (PIP) process. The semiconductor memory device includes isolation layers defining a tunneling region and a read transistor region of a semiconductor substrate, a lower polysilicon film formed on and/or over the tunneling region and the read transistor region, a dielectric film formed on and/or over the lower polysilicon film in the tunneling region, and an upper polysilicon film formed on and/or over the dielectric film.