DIVIDEND NOTICE
COMSTOCK FUNDS
FOR IMMEDIATE RELEASE
Rye, New York
December 27, 2001
 

The Comstock Funds listed below announced year-end distributions. The distributions are entirely from net investment income and are payable December 27, 2001 to shareholders of record on December 26, 2001. The ex-dividend, payment and reinvestment date is December 27, 2001.

  Source of Distribution (per share)
  Total Net
Invest.

Income
Short
Term

Cap Gains(a)
Long
Term

Cap Gains
Strategy Fund Cl. O (CPSFX) $0.0131 $0.0131 ---- ----
Strategy Fund Cl. A (CPFAX) $0.0122 $0.0122 ---- ----
Strategy Fund Cl. C (CPFCX) $0.0091 $0.0091 ---- ----
Capital Value Fund Cl. A (DRCVX) $0.1497 $0.1497 ---- ----
Capital Value Fund Cl. B (DCVBX) $0.1314 $0.1314 ---- ----
Capital Value Fund Cl. C (CPCCX) $0.1272 $0.1272 ---- ----
Capital Value Fund Cl. R (CPCRX) $0.1587 $0.1587 ---- ----

The Comstock Funds are managed by Gabelli Funds, LLC and distributed by Gabelli & Company, Inc., subsidiaries of Gabelli Asset Management Inc., which is a publicly traded NYSE listed company.

For further information call Bruce Alpert at 914-921-5105 or 1-800-GABELLI (1-800-422-3554).