The Gabelli Funds listed below announced year-end distributions. The distributions are payable December 29, 2004 to shareholders of record on December 28, 2004. The ex-dividend, payment and reinvestment date is December 29, 2004.

Source of Distribution (per share)   Total Net Invest. Income Short Term Cap Gains(a) Long Term Cap Gains Asset Fund Class AAA (GABAX) $0.7900 $0.0252 $0.0360 $0.7288 Class A (GATAX) $0.8483 $0.0835 $0.0360 $0.7288 Class B (GATBX) $0.7648 --- $0.0360 $0.7288 Class C (GATCX) $0.7820 $0.0172 $0.0360 $0.7288 Equity Income Fund Class AAA (GABEX) $0.3311 $0.0190 $0.0631 $0.2490 Class A (GCAEX) $0.3611 $0.0490 $0.0631 $0.2490 Class B (GCBEX) $0.3121 --- $0.0631 $0.2490 Class C (GCCEX) $0.3381 $0.0260 $0.0631 $0.2490 Global Opportunity Fund Class AAA (GABOX) $0.0465 $0.0465 --- --- Class A (GOCAX) $0.0521 $0.0521 --- --- Class B $0.0254 $0.0254 --- --- Class C None --- --- --- Value Fund Class A (GABVX) $0.7739 --- $0.0257 $0.7482 Class B (GVCBX) $0.7739 --- $0.0257 $0.7482 Class C (GVCCX) $0.7739 --- $0.0257 $0.7482 International Growth Fund Class AAA (GIGRX) $0.0537 $0.0537 --- --- Class A (GAIGX) $0.0593 $0.0593 --- --- Class B (GBIGX) None --- --- --- Class C (GCIGX) None --- --- --- ABC Fund (GABCX) $0.1700 $0.0760 $0.0940 --- Global Telecom Fund Class AAA (GABTX) $0.0790 $0.0790 --- --- Class A (GTCAX) $0.0800 $0.0800 --- --- Class B (GTCBX) None --- --- --- Class C (GTCCX) $0.0500 $0.0500 --- --- Gabelli Gold Fund Class AAA (GOLDX) $0.2000 $0.2000 --- --- Class A (GLDAX) $0.2220 $0.2220 --- --- Class B (GLDBX) $0.0780 $0.0780 --- --- Class C (GLDCX) $0.0930 $0.0930 --- --- Ned Davis Research Asset Allocation Class AAA (NDRAX) $0.1610 --- $0.1396 $0.0214 Class A (NDRQX) $0.1610 --- $0.1396 $0.0214 Class B (NDRBX) $0.1610 --- $0.1396 $0.0214 Class C (NDRCX) $0.1610 --- $0.1396 $0.0214 Class I (NDRIX) $0.1610 --- $0.1396 $0.0214 Comstock Strategy Fund Class O (CPSFX) $0.0609 $0.0609 --- --- Class A (CPFAX) $0.0494 $0.0494 --- --- Class C (CPFCX) $0.0283 $0.0283 --- --- Blue Chip Value Fund Class AAA (GABBX) $0.0336 $0.0336 --- --- Class A (GBCAX) $0.0386 $0.0386 --- --- Class B GBCBX() None --- --- --- Class C (GBCCX) None --- --- --- Class I $0.0657 $0.0657 --- --- Global Growth Fund Class AAA (GICPX) None --- --- --- Class A (GGGAX) None --- --- --- Class B (GGGBX) None --- --- --- Class C (GGGCX) None --- --- --- Comstock Capital Value Fund Class A (DRCVX) None --- --- --- Class B (DCVBX) None --- --- --- Class C (CPCCX) None --- --- --- Class R (CPCRX) None --- --- --- Growth Fund Class AAA (GABGX) None --- --- --- Class A None --- --- --- Class B None --- --- --- Class C None --- --- --- Mathers (MATRX) None --- --- ---   Variable Annuities Gabelli Capital Asset Fund (a) $0.7151 $0.0590 $0.1346 $0.5215 (a) ) The Gabelli Capital Asset Fund is an investment option for The Guardian Investor, a variable annuity issued by The Guardian Insurance & Annuity Company.

The Gabelli Funds are managed by Gabelli Funds, LLC and distributed by Gabelli & Company, Inc.

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