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

FOR IMMEDIATE RELEASE
Rye, New York
September 28, 2005


    The Comstock Strategy Fund will pay the following quarterly distributions of net investment income:

    Share Class Distribution Rate
    (per share)
    Record Date Ex-Dividend, Payment
    & Reinvestment Date
    Class O -Fund #1791
    (CPSFX - Nasdaq)
    $0.015 September 27, 2005 September 28, 2005
    Class A -Fund #1789
    (CPFAX - Nasdaq)
    $0.012 September 27, 2005 September 28, 2005
    Class C -Fund #1790
    (CPFCX - Nasdaq)
    None September 27, 2005 September 28, 2005

    The Comstock Funds are managed by Gabelli Funds, LLC and distributed by Gabelli & Company, Inc., subsidiaries of GAMCO Investors, Inc. which is a publicly traded NYSE listed company. (NYSE:GBL)

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