COMSTOCK PARTNERS FUNDS INC
497, 1999-08-27
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                         COMSTOCK PARTNERS FUNDS, INC.


     Supplement dated August 28, 1999 to Prospectus dated August 28, 1999



          On June 1, 1999, the Company commenced legal action in the U.S.
District Court for the District of New Jersey with respect to the
distribution arrangements of the Strategy Fund and the Capital Value Fund.
The Company has alleged, among other things, that Funds Distributor, Inc. has
interfered with a contractual relationship between Premier Mutual Fund
Services, Inc., the distributor to the Strategy Fund and the Capital Value
Fund. Although management of the Company believes it will prevail on these
claims, there can be no assurance that the Company will prevail or that the
Funds' existing distribution agreements will continue in effect.




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