DIVIDEND NOTICE
THE COMSTOCK FUNDS, INC. - COMSTOCK STRATEGY FUND

FOR IMMEDIATE RELEASE
Rye, New York
June 28, 2005


    The Comstock Strategy Fund will pay the following quarterly distributions:

    Share Class Distribution Rate
    (per share)
    Record Date Ex-Dividend, Payment
    & Reinvestment Date
    Class O -Fund #1791
    (CPSFX - Nasdaq)
    $0.006 June 27, 2005 June 28, 2005
    Class A -Fund #1789
    (CPFAX - Nasdaq)
    $0.005 June 27, 2005 June 28, 2005
    Class C -Fund #1790
    (CPFCX - Nasdaq)
    $0.001 June 27, 2005 June 28, 2005

    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 N. Alpert at 914-921-5105 or 1-800-GABELLI (1-800-422-3554).