COMSTOCK FUNDS INC
N-30D, 2001-01-04
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                              COMSTOCK FUNDS, INC.
                               SEMI-ANNUAL REPORT
                                OCTOBER 31, 2000

TO OUR SHAREHOLDERS,

      The potential bear market that we discussed in our April 30 letter has now
become a reality.  At the recent  market low, the Nasdaq  Composite was down 50%
from its peak and the S&P 500 was down 16%.  Earlier this year, the stock market
exhibited  the signs of a classic  major top,  characterized  by extremely  high
valuation,  an overheating economy, labor shortages,  creeping inflation,  tight
monetary  policy and poor  breadth.  Furthermore,  the  massive  movement of the
general public into equities marked one of the great historical financial manias
in history,  ranking with the U.S.  market in 1929, the Japanese market in 1989,
as well as other great manias of past centuries.  Despite the decline  witnessed
to date, we believe the bear market still has a long way to go.

INVESTMENT PERFORMANCE*

      For the six months ended  October 31, 2000,  the  Comstock  Capital  Value
Fund's Class A, B, C and R shares  posted total returns of 1.10%,  1.11%,  0.77%
and 1.85%,  respectively.  The Comstock  Strategy Fund's Class O, A and C shares
declined 2.94%,  3.06%, and 3.44%,  respectively.  The Standard & Poor's ("S&P")
500 Index and the Lehman Brothers  Government/Corporate Bond ("LBG/C") Index had
a total return of 1.02% and 2.04%, respectively, over the same six-month period.
Each index is an unmanaged  indicator of  investment  performance.  The Comstock
Capital Value Fund's Class A, B, C and R shares declined 12.29%, 12.92%, 13.20%,
and 11.66%,  respectively,  over the trailing  twelve-month period. The Comstock
Strategy  Fund's  Class O, A and C shares  declined  8.24%,  8.48%,  and  8.79%,
respectively, over the same twelve-month period. The S&P 500 and the LGB/C Index
rose 6.08% and 7.13%, respectively, over the same twelve-month period.

COMMENTARY

      Although the market has come down recently,  it is still highly overvalued
by historic standards. For 71 years between 1926 and 1997, the S&P 500 sold at a
price-earnings  ("PE")  ratio  between  7 on the low side and 21 on the high end
(excluding  recessions or depressions),  with an overall average of about 15. By
earlier this year,  however,  the PE ratio reached an astounding  32, a full 50%
higher than the
                                     <PAGE>

peak during any previous bull market.  Even now, the S&P 500 sells at a PE ratio
of 25, a level  that is 19%  higher  than any  previous  bull  market top and an
amazing 67% above its 74-year average. The Nasdaq Composite,  with a much higher
percentage of technology stocks, is even more grossly overvalued. Until 1997, it
had never  traded at a PE ratio of more than 45, and had earlier sold between 18
and 28 times earnings. The Nasdaq then exploded in a parabolic rise that carried
the PE ratio to 280 early this year, and even after a substantial decline, saw a
PE ratio of about 105 times earnings at its recent lows.

      Six Federal  Reserve Board  tightenings  totaling 175 basis points between
June 1999 and May 2000 have succeeded in slowing down the economy.  In addition,
some 150 central bank interest rate hikes worldwide over the same period are now
slowing down the global economy as well. We are now witnessing  either declining
rates of growth or outright declines in consumer spending, capital expenditures,
industrial  production and employment.  Corporate  earnings estimates are coming
down rapidly.  The downgrades are widespread,  including both technology and the
old economy. The slowdown in technology is particularly significant,  since this
area has been the main driver of economic  growth in recent  years.  In the past
two months  alone the  estimated  increases in S&P 500 fourth  quarter  earnings
estimates  have  dropped  from 15% to 8%,  and a slew of new  downgrades  appear
daily.  Although most economists are still counting on a soft landing,  the odds
of a hard landing are increasing  rapidly.  A study of history  indicates that a
hard landing is a strong possibility that should not be easily dismissed.  Eight
of the ten past periods of Federal  Reserve  Board  tightening  were followed by
recessions,  and only two by soft  landings.  Indeed,  soft landings have been a
rare  occurrence in U.S.  financial  history.  Economists  estimate that the lag
between a hike in interest rates and its negative effect on the economy is about
a year.  Therefore the rate increases  initiated in the first five months of the
year are likely to keep  hitting the  economy  well into 2001.  With  industrial
production and retail sales already  declining,  it is entirely possible that we
are in a recession now.

      As a result of the weak  economy,  the Fed is now  shifting  away from its
tightening  bias,  and  will  eventually  ease  if  the  economy   continues  to
deteriorate.  Unfortunately, however, it often takes two or more easing moves to
get the  market  moving  on an upward  path.  The S&P 500 fell 27% after the Fed
started  to ease in 1974 and fell 16%  after  they  began to ease in 1981.  This
happens because the  deteriorating  conditions that finally  convince the Fed to
ease are extremely harmful to corporate earnings. An easier monetary policy will
eventually  revive  the  market,  but  only  after  the  majority  of  investors
capitulate and bring stocks down to either cheap or reasonable values.

      That investors have not yet  capitulated is indicated by their  continuing
bullish attitude toward stocks.  The prevalence of high PE ratios cited above is
one  important   indication  of  this   attitude.   Another  is  the  Investor's
Intelligence  survey showing a continued high preponderance of bulls over bears.
Historically,  bull  market  peaks have been  marked by a high ratio of bulls to
bears,  while the opposite is true at bottoms.  Currently the bull-bear ratio is
much more indicative of a market top than a bottom.

                                        2
                                     <PAGE>

CONCLUSION

      In summary,  we believe  that the bear market will  continue  until stocks
sell at reasonable  values and reflect the reduced  expectations for the economy
and  corporate  earnings.  Since the S&P 500 and the Nasdaq  Composite are still
selling far above fair value,  the decline from this point could be severe.  The
Comstock Funds are positioned to benefit from a continuing  market downturn with
a combination  of index puts and shorts of individual  stocks and index futures.
We have also added a position in 30-year  Treasuries,  which should benefit from
falling long rates in a softer economy.

                                         Sincerely,

             /S/ SIGNATURE                                  /S/ SIGNATURE

             CHARLES L. MINTER                              MARTIN WEINER, CFA
             Portfolio Manager                              Portfolio Manager
             and Director                                   and President

December 15, 2000

* PERFORMANCE INFORMATION:

  Total return  assumes the  reinvestment  of dividends  and  distributions  and
  excludes the effect of sales loads.  See  Standardized  Performance on Page 4.
  Past performance is no guarantee of future results. Investment returns and the
  principal value of an investment will fluctuate. Shares, when redeemed, may be
  worth more or less than their original cost.  Returns reflect changes in share
  price,  reinvested  dividends and capital  gains and are net of expenses.  The
  prospectus  contains more complete  information,  including fees and expenses.
  Read it carefully before you invest or send money.

  The Standard & Poor's 500 Index is a widely accepted  unmanaged index of stock
  market  performance  which reflects the  reinvestment of income dividends and,
  where   applicable,   capital   gain   distributions.   The  Lehman   Brothers
  Government/Corporate  Bond Index is a widely accepted  unmanaged index of bond
  market  performance which includes fixed rate issues rated investment grade or
  higher; all returns are market value weighted inclusive of accrued interest.

  Investors  should note that there can be no  assurance  that the markets  will
  perform  according  to the  investment  adviser's  expectations  or  that  the
  adviser's investment approach will achieve its objectives.

--------------------------------------------------------------------------------
  You may obtain current  information  about Comstock Strategy Fund and Comstock
  Capital Value Fund and our investment  strategy  through our internet web site
  www.comstockfunds.com or call our telephone information line 1-800-GABELLI.
  Please save this information for future reference.
--------------------------------------------------------------------------------

                                        3
                                     <PAGE>

AVERAGE ANNUAL TOTAL RETURNS
FOR THE PERIODS ENDED OCTOBER 31, 2000
--------------------------------------------------------------------------------

<TABLE>
<CAPTION>
                                                                                                      SINCE FUND'S
COMSTOCK STRATEGY FUND, INC. (A)                        ONE YEAR       FIVE YEARS     TEN YEARS    INCEPTION (5/26/88)
---------------------------------------------------------------------------------------------------------------------------
<S>                                                     <C>             <C>            <C>                <C>
 CLASS O
  Without sales charge...........................        (8.24)%         (9.27)%       (1.87)%            0.88%
  With sales charge (c)..........................       (12.37)%        (10.10)%       (2.32)%            0.51%
---------------------------------------------------------------------------------------------------------------------------
 CLASS A
  Without sales charge...........................        (8.48)%         (9.51)%       (2.10)%            0.69%
  With sales charge (c)..........................       (12.60)%        (10.34)%       (2.55)%            0.32%
---------------------------------------------------------------------------------------------------------------------------
 CLASS C
  Without contingent deferred sales charge.......        (8.79)%        (10.15)%       (2.45)%            0.39%
  With contingent deferred sales charge (d)......        (9.71)%        (10.15)%       (2.45)%            0.39%
---------------------------------------------------------------------------------------------------------------------------



<CAPTION>
                                                                                       SINCE POLICY       SINCE FUND'S
COMSTOCK CAPITAL VALUE FUND, INC. (B)              ONE YEAR   FIVE YEARS   TEN YEARS   INCEPTION (E)   INCEPTION (10/10/85)
-----------------------------------------------------------------------------------------------------------------------------
<S>                                                <C>         <C>          <C>         <C>                <C>
 CLASS A
  Without sales charge....................         (12.29)%    (17.50)%      (9.87)%     (3.86)%           (0.87)%
  With sales charge (c)...................         (16.24)%    (18.26)%     (10.28)%     (4.15)%           (1.18)%
-----------------------------------------------------------------------------------------------------------------------------
 CLASS B
  Without contingent deferred sales charge         (12.92)%    (18.14)%     (10.44)%     (4.27)%           (1.29)%
  With contingent deferred sales charge (f)        (16.40)%    (18.47)%     (10.44)%     (4.27)%           (1.29)%
-----------------------------------------------------------------------------------------------------------------------------
 CLASS C
  Without contingent deferred sales charge         (13.20)%    (18.10)%     (10.43)%     (4.26)%           (1.28)%
  With contingent deferred sales charge (d)        (14.07)%    (18.10)%     (10.43)%     (4.26)%           (1.28)%
-----------------------------------------------------------------------------------------------------------------------------
 CLASS R..................................         (11.66)%    (17.21)%      (9.70)%     (3.74)%           (0.75)%
-----------------------------------------------------------------------------------------------------------------------------


<FN>
(a)The total return  reflects the deduction of the maximum  initial sales charge
   of 4.5% when the Fund last  offered  Class O shares.  Total  return  prior to
   8/01/91 reflects performance of the Fund as a closed-end fund; as an open-end
   fund  the  Fund  incurs  certain  additional  expenses  as a  result  of  the
   continuous offering and redemption of its shares.  Because Class A shares and
   Class C shares  were not  actually  introduced  until  7/15/92  and  8/01/95,
   respectively,  total return for the period prior to the  introduction of each
   such class (i) reflects the  performance  information  for Class O shares and
   Class A shares, as appropriate (ii) does not reflect service and distribution
   fees borne by Class A shares and Class C shares,  which, if reflected,  would
   reduce the total return  presented.  Total return assumes the reinvestment of
   dividends and capital gains distributions.

(b)The total return is based upon a  hypothetical  investment  in Class A shares
   at the Fund's  inception  on  10/10/85,  assuming  the current  4.5%  maximum
   initial  sales  charge for Class A shares.  Because  Class B shares  were not
   actually  introduced until 1/15/93 and Class C shares and Class R shares were
   not actually  introduced until 8/22/95,  total return for the period prior to
   the  introduction  of each such  class (i) in the case of Class B shares  and
   Class R shares,  reflects the performance information for Class A shares (ii)
   in the case of Class C shares, reflects the performance information for Class
   A shares and Class B shares,  as appropriate and (iii) in the case of Class B
   shares and Class C shares,  does not reflect higher service and  distribution
   fees and certain administrative  expenses borne by Class B shares and Class C
   shares, which, if reflected,  would reduce the total return presented.  Total
   return assumes the reinvestment of dividends and capital gains distributions.

(c)Assuming maximum initial sales charge of 4.5%

(d)Assuming  payment of the maximum  contingent  deferred sales charge (CDSC). A
   CDSC of 1% is imposed on redemptions made within one year of purchase.

(e)On April  28,  1987,  Comstock  Partners,  Inc.,  the  Capital  Value  Fund's
   Investment Adviser, assumed investment  responsibilities and the Fund changed
   its investment objective to the current investment objective.

(f)Assuming payment of the maximum contingent  deferred sales charge (CDSC). The
   maximum CDSC for Class B shares is 4% and is reduced to 0% after six years.


</FN>
</TABLE>

                                        4
                                     <PAGE>

COMSTOCK STRATEGY FUND, INC.
SCHEDULE OF INVESTMENTS -- OCTOBER 31, 2000 (UNAUDITED)
-----------------------------------------------------------

   PRINCIPAL                                        MARKET
    AMOUNT                             COST         VALUE
    ------                             ----         -----

              U.S. GOVERNMENT OBLIGATIONS -- 96.1%
              U.S. TREASURY BILLS -- 1.3%
    345,000   U.S. Treasury Bill,
               6.34%++, 01/25/01 ..    339,978      339,974
                                   -----------  -----------
              U.S. TREASURY NOTES -- 94.8%
              U.S. Treasury Notes,
$ 2,664,000    8.50%, 11/15/00 ... $ 2,670,699  $ 2,665,769
  5,260,000    6.38%, 01/31/02 ...   5,243,523    5,269,194
 11,600,000    6.38%, 04/30/02 ...  11,531,838   11,645,831
  5,400,000    6.00%, 08/15/09 ...   5,225,643    5,457,764
                                   -----------  -----------
                                    24,671,703   25,038,558
                                   -----------  -----------
              TOTAL U.S. GOVERNMENT
               OBLIGATIONS .......  25,011,681   25,378,532
                                   -----------  -----------
              TOTAL
               INVESTMENTS -- 96.1%$25,011,681   25,378,532
                                   ===========
              OTHER ASSETS AND
               LIABILITIES (NET) -- 3.9% ......   1,037,495
                                                -----------
              NET ASSETS -- 100.0%
               (6,852,489 shares outstanding)   $26,416,027
                                                ===========

    NUMBER OF                      EXPIRATION DATE/  MARKET
    CONTRACTS    ISSUE              EXERCISE PRICE   VALUE
    ---------    -----             ----------------  -----
              PUT OPTIONS PURCHASED
         25   S & P 500 Index ...... Dec. 00/1275  $ 15,625
        280   S & P 500 Index ...... Dec. 00/1300   231,000
        120   S & P 500 Index ...... Mar. 01/1300   265,500
         50   S & P 500 Index ...... June 01/1300   409,500
                                                   --------
    Total Put Options Purchased (Cost $1,874,385)  $921,625
                                                   ========
------------------------
++   Represents annualized yield at date of purchase.

                 See accompanying notes to financial statements.

                                        5
                                     <PAGE>

COMSTOCK CAPITAL VALUE FUND, INC.
SCHEDULE OF INVESTMENTS -- OCTOBER 31, 2000 (UNAUDITED)
-------------------------------------------------------------------------

   PRINCIPAL                                                     MARKET
    AMOUNT                                         COST          VALUE
    ------                                         ----          -----


              U.S. GOVERNMENT OBLIGATIONS -- 85.9%
              U.S. TREASURY BILLS -- 85.9%
$31,776,000   U.S. Treasury Bills,
               6.13% to 6.25%++,
               due 11/02/00 to 01/04/01         $31,444,589   $31,439,410
                                                -----------   -----------
              TOTAL
               INVESTMENTS -- 85.9%             $31,444,589    31,439,410
                                                ===========
              OTHER ASSETS AND
               LIABILITIES (NET) -- 14.1% ..................    5,152,777
                                                              -----------
              NET ASSETS -- 100.0%
               (13,343,306 shares outstanding) .............  $36,592,187
                                                              ===========

                                                     MARKET
    COMMON STOCKS             SHARES   PROCEEDS      VALUE
    -------------             ------   --------      -----
    SECURITIES SOLDSHORT
    Amazon.com Inc.           9,400 $   607,572  $  344,275
    Apple Computer Inc        9,800     451,032     191,712
    Applied Materials Inc.    6,000     521,623     318,750
    Ariba Inc.                3,300     372,475     417,037
    Avaya Inc.                  750      29,403      10,078
    Broadcom Co.              1,500     344,524     333,563
    Cisco Systems Inc.        7,300     501,037     393,287
    CMGI Inc.                 5,400     577,848      91,125
    CNET Networks Inc.        9,000     481,096     283,500
    Dell Computer Corp.      10,000     477,509     295,000
    Disney (Walt) Co.        10,000     345,738     358,125
    Electronic Data
      Systems Corp.           6,500     401,849     305,094
    EMC Corp.                 4,500     381,700     400,781
    Global Crossing Ltd.     11,500     482,409     271,688
    Hewlett Packard Co.      14,000     742,868     650,125
    Internet Capital Group
     Inc.                     6,300     569,029      83,475
    Level 3 Communications
     Inc.                     5,600     591,200     267,050
    Lucent Technologies Inc.  9,000     460,643     209,813
    Micron Technology Inc.    9,000     686,237     312,750
    Nasdaq 100 Trust         18,000   1,592,609   1,472,625
    Oracle Corp.             13,000     506,252     429,000
    PMCS                      1,800     363,367     305,100
    Sanchez Computer
      Associates Inc.        13,800     464,182     221,663
    SDL Inc                   1,300     377,394     337,025
    Sun Microsystems          3,200     352,196     354,800
    Xilinx Inc.              10,000     699,515     724,375
    Yahoo! Inc.               3,200     566,221     187,600
                                     ----------  ----------
    TOTAL SECURITIES
      SOLD SHORT                    $13,947,528  $9,569,416
                                    ===========  ==========


    NUMBER OF                      EXPIRATION DATE/      MARKET
    CONTRACTS    ISSUE              EXERCISE PRICE       VALUE
    ---------    -----             ----------------      -----
              PUT OPTIONS PURCHASED
         75   S & P 500 Index ...... Dec. 00/1275      $  46,875
        410   S & P 500 Index ...... Dec. 00/1300        338,250
        180   S & P 500 Index ...... Mar. 01/1300        398,250
         80   S & P 500 Index ...... June 01/1300        273,000
                                                      ----------
    Total Put Options Purchased (Cost $2,498,695)     $1,056,375
                                                      ==========

                                                     UNREALIZED
                                                    APPRECIATION
                                                    ------------
              FUTURE CONTRACTS -- SHORT POSITION
         40   S&P 500 Index Futures ....... 12/15/00  $549,000
                                                      ========
------------------------
++   Represents annualized yield at date of purchase.

                 See accompanying notes to financial statements.

                                        6
                                     <PAGE>

COMSTOCK FUNDS, INC.
STATEMENT OF ASSETS AND LIABILITIES
OCTOBER 31, 2000 (UNAUDITED)
--------------------------------------------------------------------------------
<TABLE>
<CAPTION>

                                                                                           STRATEGY      CAPITAL VALUE
                                                                                             FUND            FUND
                                                                                         ------------    -------------
<S>                                                                                      <C>             <C>
ASSETS:
   Investments at value (Cost $25,011,681 and $31,444,589, respectively).............    $ 25,378,532    $ 31,439,410
   Put options purchased (Cost $1,874,385 and $2,498,695, respectively)..............         921,625       1,056,375
   Cash..............................................................................           1,017           2,396
   Interest receivable...............................................................         260,059         213,390
   Receivable for Fund shares sold...................................................          18,963              --
   Receivable for investments sold...................................................              --      13,947,528
   Prepaid expenses..................................................................          10,597          17,025
                                                                                         ------------    ------------
   TOTAL ASSETS......................................................................      26,590,793      46,676,124
                                                                                         ------------    ------------
LIABILITIES:
   Securities sold short (proceeds $13,947,528)......................................              --       9,569,416
   Dividend payable on securities sold short.........................................              --           5,418
   Payable for Fund shares redeemed..................................................           1,199         101,796
   Payable for investment advisory fees..............................................          19,840          28,047
   Payable for distribution fees.....................................................             778          14,458
   Variation margin..................................................................              --         290,000
   Other accrued expenses............................................................         152,949          74,802
                                                                                         ------------    ------------
   TOTAL LIABILITIES.................................................................         174,766      10,083,937
                                                                                         ------------    ------------
   NET ASSETS........................................................................    $ 26,416,027    $ 36,592,187
                                                                                         ============    ============
NET ASSETS CONSIST OF:
   Paid in capital...................................................................    $124,812,066    $299,232,262
   Accumulated undistributed net investment income...................................          75,810       3,755,403
   Accumulated net realized loss on investments, put options purchased,
     futures and short sale transactions.............................................     (97,885,940)   (269,875,091)
   Net unrealized appreciation on short sale transactions............................              --       4,378,112
   Net unrealized depreciation on investments, put options purchased
     and futures transactions........................................................        (585,909)       (898,499)
                                                                                         ------------    ------------
   NET ASSETS........................................................................    $ 26,416,027    $ 36,592,187
                                                                                         ============    ============

SHARES OF COMMON STOCK OUTSTANDING:
   CLASS O:
     Net Asset Value, offering and redemption price per share
       (6,076,947 shares outstanding) ...............................................          $ 3.85
                                                                                               ======
   CLASS A:
     Net Asset Value and redemption price per share
       (733,306 and 9,777,697 shares outstanding, respectively)......................          $ 3.85          $ 2.75
                                                                                               ======          ======
     Maximum offering price per share (NAV (divide) 0.955 based on maximum sales charge
       of 4.50% of the offering price at October 31, 2000)...........................          $ 4.03          $ 2.88
                                                                                               ======          ======
   CLASS B:
     Net Asset Value and offering price per share (2,742,081 shares outstanding).....                          $ 2.74(a)
                                                                                                               ======
   CLASS C:
     Net Asset Value and offering price per share
       (42,236 and 822,939 shares outstanding, respectively).........................          $ 3.87(a)       $ 2.63(a)
                                                                                               ======          ======
   CLASS R:
     Net Asset  Value, offering and redemption price per share (588  shares
       outstanding) .................................................................                          $ 2.76
                                                                                                               ======
<FN>
--------------------------------
(a) Redemption price varies based on length of time held.
</FN>
</TABLE>

                 See accompanying notes to financial statements.

                                       7
                                     <PAGE>

COMSTOCK FUNDS, INC.
STATEMENT OF OPERATIONS
FOR THE SIX MONTHS ENDED OCTOBER 31, 2000 (UNAUDITED)
--------------------------------------------------------------------------------

<TABLE>
<CAPTION>
                                                                                            STRATEGY     CAPITAL VALUE
                                                                                              FUND            FUND
                                                                                          ------------    -------------
<S>                                                                                        <C>            <C>
INVESTMENT INCOME:
   Interest..........................................................................      $  811,094     $ 1,689,379
                                                                                           ----------     -----------
   TOTAL INVESTMENT INCOME...........................................................         811,094       1,689,379
                                                                                           ----------     -----------
EXPENSES:
   Investment advisory fees..........................................................         125,109         213,186
   Distribution fees.................................................................           5,113          93,261
   Shareholder services fees.........................................................         116,854          66,075
   Legal and audit fees..............................................................          35,178          33,348
   Registration fees.................................................................          22,899          19,100
   Shareholder communications expenses...............................................          12,065          21,179
   Directors' fees...................................................................           7,702          10,950
   Custodian fees....................................................................           1,035           3,303
   Dividends on securities sold short................................................              --           5,418
   Miscellaneous expenses............................................................          14,944          24,970
                                                                                           ----------     -----------
   TOTAL EXPENSES....................................................................         340,899         490,790
   LESS:
     Expense reimbursements..........................................................              --         (42,535)
                                                                                           ----------     -----------
   TOTAL NET EXPENSES................................................................         340,899         448,255
                                                                                           ----------     -----------
NET INVESTMENT INCOME................................................................         470,195       1,241,124
                                                                                           ----------     -----------
NET REALIZED AND UNREALIZED LOSS ON INVESTMENTS,
   PUT OPTIONS AND FUTURES TRANSACTIONS:
   Net realized loss on investments, put options and futures transactions............      (1,999,624)     (3,650,679)
   Net realized loss on securities sold short transactions...........................              --      (1,854,144)
   Net change in net unrealized depreciation on investments, put options
      and futures transactions ......................................................         698,014         133,122
   Net change in net unrealized appreciation on securities sold short transactions...              --       2,636,367
                                                                                           ----------     -----------
   NET REALIZED AND UNREALIZED LOSS ON INVESTMENTS, PUT OPTIONS
     AND FUTURES TRANSACTIONS........................................................      (1,301,610)     (2,735,334)
                                                                                           ----------     -----------
   NET DECREASE IN NET ASSETS RESULTING FROM OPERATIONS..............................      $ (831,415)    $(1,494,210)
                                                                                           ==========     ===========
</TABLE>




                 See accompanying notes to financial statements.

                                        8
                                     <PAGE>

COMSTOCK FUNDS, INC.
STATEMENT OF CHANGES IN NET ASSETS
--------------------------------------------------------------------------------

<TABLE>
<CAPTION>
                                                                 STRATEGY FUND                CAPITAL VALUE FUND
                                                       ------------------------------- -------------------------------
                                                       SIX MONTHS ENDED                SIX MONTHS ENDED
                                                       OCTOBER 31, 2000   YEAR ENDED   OCTOBER 31, 2000   YEAR ENDED
                                                         (UNAUDITED)    APRIL 30, 2000    (UNAUDITED)   APRIL 30, 2000
                                                       ---------------- -------------- ---------------- --------------
<S>                                                       <C>             <C>             <C>             <C>
OPERATIONS:
   Net investment income............................      $   470,195     $ 1,864,404     $ 1,241,124     $ 2,514,309
   Net realized loss on investments,
     put options and futures transactions...........       (1,999,624)    (11,682,811)     (3,650,679)    (15,365,820)
   Net realized loss on short sale transactions.....               --              --      (1,854,144)     (6,539,009)
   Net change in net unrealized depreciation on
     investments, put options and futures transactions        698,014       3,061,143       1,231,122       2,042,595
   Net change in net unrealized appreciation
     on short sale transactions.....................               --              --       2,636,367       1,556,390
                                                          -----------     -----------     -----------     -----------
   NET DECREASE IN NET ASSETS
     RESULTING FROM OPERATIONS......................         (831,415)     (6,757,264)       (396,210)    (15,791,535)
                                                          -----------     -----------     -----------     -----------
DIVIDENDS TO SHAREHOLDERS:
   Net investment income
     Class O........................................         (469,440)     (1,610,240)                             --
     Class A........................................          (56,170)       (233,701)                       (851,889)
     Class B........................................               --              --                         (11,654)
     Class C........................................           (2,286)        (15,205)                             --
     Class R........................................               --              --                            (340)
                                                          -----------     -----------                     -----------
   TOTAL DISTRIBUTIONS TO SHAREHOLDERS..............         (527,896)     (1,859,146)                       (863,883)
                                                          -----------     -----------                     -----------
CAPITAL STOCK TRANSACTIONS:
   Proceeds from shares sold:
     Class O........................................          172,401              --              --              --
     Class A........................................          521,665         444,503       2,367,675      32,351,340
     Class B........................................               --              --       1,409,015       4,853,966
     Class C........................................              888         414,162          69,028       2,438,625
     Class R........................................               --              --             550              --
                                                          -----------     -----------     -----------     -----------
                                                              694,954         858,665       3,846,268      39,643,931
                                                          -----------     -----------     -----------     -----------
   Proceeds from reinvestment of dividends:
     Class O........................................          134,456         414,230                              --
     Class A........................................           23,129          94,722                         491,960
     Class B........................................               --              --                           6,822
     Class C........................................            1,263           4,230                              --
     Class R........................................               --              --                             334
                                                          -----------     -----------                     -----------
                                                              158,848         513,182                         499,116
                                                          -----------     -----------                     -----------
     Class O........................................       (3,536,688)    (11,005,330)             --              --
     Class A........................................       (1,354,513)     (3,445,035)    (14,074,497)    (39,944,149)
     Class B........................................               --              --      (1,906,601)     (8,005,008)
     Class C........................................          (42,144)       (820,862)       (292,082)     (4,140,687)
     Class R........................................               --              --          (3,347)        (20,765)
                                                          -----------     -----------     -----------     -----------
                                                           (4,933,345)    (15,271,227)    (16,276,527)    (52,110,609)
                                                          -----------     -----------     -----------     -----------
   Net decrease in net assets
     from capital stock transactions................       (4,079,543)    (13,899,380)    (12,430,259)    (11,967,562)
                                                          -----------     -----------     -----------     -----------
   NET DECREASE IN NET ASSETS.......................       (5,438,854)    (22,515,790)    (12,826,469)    (28,622,980)
                                                          -----------     -----------     -----------     -----------
NET ASSETS:
   Beginning of period..............................       31,854,881      54,370,671     (49,418,656)     78,041,636
                                                          -----------     -----------     -----------     -----------
   End of period....................................      $26,416,027     $31,854,881     $36,592,187     $49,418,656
                                                          ===========     ===========     ===========     ===========
   Undistributed net investment income..............      $    75,810     $   133,511     $ 3,755,403     $ 2,514,279
                                                          ===========     ===========     ===========     ===========

</TABLE>



                 See accompanying notes to financial statements.

                                        9
                                     <PAGE>

COMSTOCK FUNDS, INC.
NOTES TO FINANCIAL STATEMENTS (UNAUDITED)
--------------------------------------------------------------------------------

1.  ORGANIZATION.  Comstock  Funds,  Inc.  (the  "Company"),  formerly  known as
Comstock Partners Funds, Inc., is registered under the Investment Company Act of
1940 (the "1940  Act") as an open-end  management  investment  company  offering
shares in two separate portfolios:  Comstock Strategy Fund (the "Strategy Fund")
and Comstock Capital Value Fund (the "Capital Value Fund"). The Company accounts
separately for the assets, liabilities and operations of each Fund. The Strategy
Fund is a  non-diversified  portfolio  with an investment  objective to maximize
total return over the long-term  investment horizon by investing  primarily in a
portfolio of debt securities.  The Capital Value Fund is a diversified portfolio
with an investment  objective to maximize  total  return,  consisting of capital
appreciation  and current  income.  The Strategy Fund offers Class A and Class C
shares.  The Capital  Value Fund  offers  Class A, Class B, Class C, and Class R
shares.

Each Class O, Class A and Class C share of the  Strategy  Fund and each Class A,
Class B, Class C,  andClass R share of the  Capital  Value  Fund  represents  an
interest in the Strategy  Fund or the Capital Value Fund, as the case may be, in
proportion to its net asset value, and has identical rights except that Class A,
B, and C shares of the Funds bear fees and expenses on an ongoing basis pursuant
to the Funds'  Class A,  Class B, and Class C Service  and  Distribution  Plans,
respectively,  and  Class  B and  Class C  shares  bear  additional  incremental
shareholder   administrative  expenses  resulting  from  deferred  sales  charge
arrangements.  In  addition,  only the  holders of Class A, Class B, and Class C
shares have voting  rights with  respect to matters  pertaining  to the Class A,
Class B, and Class C  Service  and  Distribution  Plans,  respectively.  Class A
shares  of each  Fund  are  subject  to a sales  charge  imposed  at the time of
purchase and in certain cases, contingent deferred sales charges. Class B shares
are  subject  to a  contingent  deferred  sales  charge  imposed  at the time of
redemption on redemptions  made within six years of purchase.  Class C shares of
each Fund are subject to a contingent  deferred sales charge imposed at the time
of redemption on  redemptions  made within one year of purchase.  Class R shares
are sold at net asset value per share only to institutional  investors.  Class O
shares are no longer offered for sale except for reinvestment of dividends.

2. SIGNIFICANT  ACCOUNTING POLICIES.  The preparation of financial statements in
accordance with generally accepted accounting  principles requires management to
make estimates and assumptions  that affect the reported amounts and disclosures
in the financial  statements.  Actual results could differ from those estimates.
The following is a summary of significant  accounting  policies  followed by the
Fund in the preparation of its financial statements.

SECURITY  VALUATION.  Portfolio  securities  listed or  traded  on a  nationally
recognized securities exchange, quoted by the National Association of Securities
Dealers Automated Quotations, Inc. ("Nasdaq") or traded on foreign exchanges are
valued at the last sale price on that  exchange  as of the close of  business on
the day the  securities  are being  valued (if there were no sales that day, the
security is valued at the  average of the  closing  bid and asked  prices or, if
there were no asked  prices  quoted on that day,  then the security is valued at
the closing bid price on that day).  All other  portfolio  securities  for which
over-the-counter  market  quotations  are  readily  available  are valued at the
latest average of the bid and asked prices.  Portfolio securities traded on more
than one  national  securities  exchange or market are valued  according  to the
broadest and most  representative  market,  as determined by Gabelli Funds,  LLC
(the  "Adviser").  Securities  and assets for which  market  quotations  are not
readily  available  are valued at their fair value as  determined  in good faith
under procedures  established by and under the general  supervision of the Board
of Directors. Short term debt securities with remaining

                                       10
                                     <PAGE>

COMSTOCK FUNDS, INC.
NOTES TO FINANCIAL STATEMENTS (CONTINUED) (UNAUDITED)
--------------------------------------------------------------------------------

maturities of 60 days or less are valued at amortized cost, unless the Directors
determine such does not reflect the securities'  fair value, in which case these
securities  will be valued at their fair value as determined  by the  Directors.
Debt  instruments  having a  maturity  greater  than 60 days are  valued  at the
highest bid price  obtained from a dealer  maintaining an active market in those
securities.

REPURCHASE  AGREEMENTS.  Each Fund may enter  into  repurchase  agreements  with
primary  government  securities dealers recognized by the Federal Reserve Board,
with member banks of the Federal Reserve System or with other brokers or dealers
that meet credit guidelines established by the Adviser and reviewed by the Board
of Directors.  Under the terms of a typical repurchase  agreement,  a Fund takes
possession  of an  underlying  debt  obligation  subject to an obligation of the
seller to  repurchase,  and a Fund to resell,  the  obligation at an agreed-upon
price and time, thereby  determining the yield during a Fund's holding period. A
Fund will always  receive and maintain  securities  as  collateral  whose market
value, including accrued interest,  will be at least equal to 100% of the dollar
amount  invested by the Fund in each  agreement.  The Fund will make payment for
such  securities  only upon  physical  delivery  or upon  evidence of book entry
transfer of the collateral to the account of the  custodian.  To the extent that
any repurchase transaction exceeds one business day, the value of the collateral
is marked-to-market on a daily basis to maintain the adequacy of the collateral.
If the seller defaults and the value of the collateral declines or if bankruptcy
proceedings   are  commenced  with  respect  to  the  seller  of  the  security,
realization of the collateral by the Fund may be delayed or limited.

OPTIONS.  Each Fund may purchase or write call or put options on  securities  or
indices. As a writer of put options, a Fund receives a premium at the outset and
then  bears  the risk of  unfavorable  changes  in the  price  of the  financial
instrument  underlying the option. A Fund would incur a loss if the price of the
underlying financial instrument decreases between the date the option is written
and the date on which the option is terminated.  A Fund would realize a gain, to
the extent of the premium,  if the price of the financial  instrument  increases
between those dates.

As a purchaser  of put  options,  a Fund pays a premium for the right to sell to
the seller of the put option the underlying  security at a specified  price. The
seller of the put has the  obligation to purchase the  underlying  security upon
exercise  at the  exercise  price.  If the  price  of  the  underlying  security
declines, a Fund would realize a gain upon sale or exercise. If the price of the
underlying  security  increases,  a Fund  would  realize  a loss upon sale or at
expiration date, but only to the extent of the premium paid.

FUTURES CONTRACTS.  Each Fund may engage in futures contracts for the purpose of
hedging  against  changes in the value of its  portfolio  securities  and in the
value of  securities  it  intends  to  purchase.  Upon  entering  into a futures
contract,  a Fund is  required  to deposit  with the broker an amount of cash or
cash equivalents equal to a certain  percentage of the contract amount.  This is
known as the "initial margin." Subsequent payments ("variation margin") are made
or received by a Fund each day,  depending on the daily fluctuation of the value
of the  contract.  The daily  changes in the contract are included in unrealized
gains or losses.  A Fund recognizes a realized gain or loss when the contract is
closed.

There are several  risks in  connection  with the use of futures  contracts as a
hedging device. The change in value of futures contracts  primarily  corresponds
with the value of their underlying instruments, which may not

                                       11
                                     <PAGE>

COMSTOCK FUNDS, INC.
NOTES TO FINANCIAL STATEMENTS (CONTINUED) (UNAUDITED)
--------------------------------------------------------------------------------

correlate with the change in value of the hedged investments. In addition, there
is the  risk  that a Fund may not be able to enter  into a  closing  transaction
because of an illiquid secondary market.

SECURITIES  SOLD SHORT. A short sale involves  selling a security which the Fund
does not own. The proceeds  received for short sales are recorded as liabilities
and a Fund records an  unrealized  gain or loss to the extent of the  difference
between the proceeds  received  and the value of the open short  position on the
day of  determination.  A Fund  records a  realized  gain or loss when the short
position is closed out. By entering  into a short sale,  a Fund bears the market
risk of an unfavorable change in the price of the security sold short. Dividends
on short sales are recorded as an expense by a Fund on the ex-dividend  date and
interest expense is recorded on the accrual basis.

FORWARD  FOREIGN  EXCHANGE  CONTRACTS.  The Funds may engage in forward  foreign
exchange contracts for hedging a specific transaction with respect to either the
currency in which the  transaction is denominated or another  currency as deemed
appropriate by the Adviser. Forward foreign exchange contracts are valued at the
forward  rate and are  marked-to-market  daily.  The  change in market  value is
included in  unrealized  appreciation/depreciation  on  investments  and foreign
currency transactions.  When the contract is closed, the Funds record a realized
gain or loss equal to the  difference  between the value of the  contract at the
time it was opened and the value at the time it was closed.

The use of forward foreign exchange contracts does not eliminate fluctuations in
the underlying prices of the Fund's portfolio securities,  but it does establish
a rate of exchange that can be achieved in the future.  Although forward foreign
exchange  contracts  limit the risk of loss due to a decline in the value of the
hedged  currency,  they also limit any potential  gain/(loss)  that might result
should the value of the  currency  increase.  In  addition,  the Funds  could be
exposed to risks if the  counterparties  to the contracts are unable to meet the
terms of their contracts.

FOREIGN CURRENCY TRANSLATION.  The books and records of the Funds are maintained
in United States  (U.S.)  dollars.  Foreign  currencies,  investments  and other
assets and liabilities  are translated  into U.S.  dollars at the exchange rates
prevailing  at the end of the  period,  and  purchases  and sales of  investment
securities,  income and expenses are translated at the exchange rate  prevailing
on the respective dates of such transactions. Unrealized gains and losses, which
result from changes in foreign exchange rates and/or changes in market prices of
securities,  have  been  included  in  unrealized  appreciation/depreciation  on
investments and foreign  currency  transactions.  Net realized  foreign currency
gains and losses  resulting  from  changes in  exchange  rates  include  foreign
currency gains and losses  between trade date and settlement  date on investment
securities  transactions,  foreign  currency  transactions  and  the  difference
between the amounts of interest and dividends recorded on the books of the Funds
and the amounts  actually  received.  The portion of foreign  currency gains and
losses  related to  fluctuation in exchange rates between the initial trade date
and  subsequent  sale  trade  date  is  included  in  realized   gain/(loss)  on
investments.

SECURITIES  TRANSACTIONS  AND INVESTMENT  INCOME.  Securities  transactions  are
accounted  for on the  trade  date  with  realized  gain or loss on  investments
determined  by using the  identified  cost method.  Interest  income  (including
amortization  of premium  and  accretion  of  discount)  is  recorded as earned.
Dividend income is recorded on the ex-dividend date.

                                       12
                                     <PAGE>


COMSTOCK FUNDS, INC.
NOTES TO FINANCIAL STATEMENTS (CONTINUED) (UNAUDITED)
--------------------------------------------------------------------------------

DIVIDENDS AND  DISTRIBUTIONS  TO  SHAREHOLDERS.  Dividends and  distributions to
shareholders  are recorded on the ex-dividend  date.  Income  distributions  and
capital  gain  distributions  are  determined  in  accordance  with  income  tax
regulations  which may differ from  generally  accepted  accounting  principles.
These differences are primarily due to differing  treatments of income and gains
on various  investment  securities  held by the Funds,  timing  differences  and
differing characterization of distributions made by the Funds.

PROVISION  FOR  INCOME  TAXES.  Each Fund  intends to  continue  to qualify as a
regulated  investment company under Subchapter M of the Internal Revenue Code of
1986, as amended. As a result, a Federal income tax provision is not required.

EXPENSES.  Certain  administrative  expenses are common to, and allocated among,
the  Portfolios.  Such  allocations  are made on the  basis of each  Portfolio's
average  net  assets  or other  criteria  directly  affecting  the  expenses  as
determined by the Adviser.

3. INVESTMENT ADVISORY  AGREEMENT.  Through May 22, 2000, the Company, on behalf
of the Funds, had engaged Comstock Partners,  Inc. (the "Investment Adviser") to
provide professional  investment management for each Fund. Under the terms of an
Amended  Investment  Advisory  Agreement  between the Company,  on behalf of the
Strategy Fund,  and the Investment  Adviser,  the Investment  Adviser  furnished
continuing  investment  supervision to the Strategy Fund and was responsible for
the  management of the Strategy  Fund's  portfolio.  It furnishes  office space,
equipment and personnel to the Strategy Fund in connection  with the performance
of its investment management responsibilities.  For its services, the Investment
Adviser received from the Company, on behalf of the Strategy Fund, a monthly fee
at an annual rate of .60% of the Strategy Fund's average daily net assets.

Under the terms of an  Investment  Advisory  Agreement  between the Company,  on
behalf of the Capital Value Fund,  and the  Investment  Adviser,  the Investment
Adviser had  responsibility  for  investment  decisions  for, and the day-to-day
management of, that portfolio. For its services, the Investment Adviser received
from the  Company,  on behalf of the Capital  Value  Fund,  a monthly fee at the
following  annual  rates:  .40% of the first $300  million of the Capital  Value
Fund's average daily net assets,  .45% of the Capital Value Fund's average daily
net assets  between $300  million and $750  million,  .50% of the Capital  Value
Fund's  average daily net assets between $750 million and $1 billion and .55% of
the Capital Value Fund's average daily net assets in excess of $1 billion.

Gabelli Funds LLC ("Gabelli") serves as Investment Adviser and Administrator for
both Funds. As compensation for services and related expenses, the Strategy Fund
pays  Gabelli an annual fee of 0.85% of the Fund's  daily  average  net  assets,
computed  daily and  payable  monthly.  The Capital  Value Fund pays  Gabelli an
annual fee of 1.0% of the Fund's daily  average net assets,  computed  daily and
payable monthly.  Gabelli has agreed to waive a portion of their fee (0.19%) for
the  Capital  Value Fund until May 2002,  to the extent  necessary,  in order to
maintain  the Fund's  expense  ratio during 1999 based on asset levels as of May
22, 2000.

Prior to May 22, 2000, under the terms of an Amended and Restated Administration
Agreement  between the Company,  on behalf of the Strategy  Fund and the Capital
Value Fund, and Princeton,  Princeton  performed or arranged for the performance
of certain administrative  services (i.e., services other than investment advice
and related  portfolio  activities)  necessary  for the  operation of the Funds,
including maintaining certain of the books

                                       13
                                     <PAGE>

COMSTOCK FUNDS, INC.
NOTES TO FINANCIAL STATEMENTS (CONTINUED) (UNAUDITED)
--------------------------------------------------------------------------------

and records of both of the Funds, preparing reports and other documents required
by United States  federal,  state and other  applicable  laws and regulations to
maintain the  registration of the Funds and their shares and providing the Funds
with  administrative  office facilities.  For the services rendered to the Funds
and the  facilities  furnished,  each Fund paid Princeton a monthly fee equal to
the  greater of (i)  $125,000  per annum or (ii) an annual rate equal to .25% of
each Fund's  average daily net assets up to $100  million,  .225% of each Fund's
average daily net assets on the next $100 million,  .20% of each Fund's  average
daily net assets on the next $400 million and .175% of each Fund's average daily
net assets in excess of $600 million.

Through May 22, 2000, the Company  compensated  Dreyfus  Transfer,  Inc. under a
transfer  agency  agreement  for providing  personnel and  facilities to perform
transfer  agency  services for the Funds.  For the six months ended  October 31,
2000, such compensation amounted to $371 for the Capital Value Fund and $151 for
the Strategy Fund.  Dreyfus Transfer,  Inc. is a wholly-owned  subsidiary of The
Dreyfus Corporation.

4.  DISTRIBUTION  PLAN. The Funds' Board of Directors has adopted a distribution
plan (the "Plan")  pursuant to Rule 12b-1 under the 1940 Act. For the six months
ended October 31, 2000,  the Capital Value Fund incurred  distribution  costs of
$37,532, $33,905 and $9,614 for Class A, Class B and Class C, respectively,  and
the Strategy Fund incurred distribution costs of $3,662 and $771 for Class A and
Class C, respectively, payable to Gabelli and Company, Inc., an affiliate of the
Adviser. Through May 22, 2000, Premier Mutual Fund Services acted as distributor
of the Funds'  shares.  Under the Class A Service  and  Distribution  Plan,  the
Company,  at the expense of the Class A shares of each Fund,  (a) reimbursed the
Distributor  for  payments  to  certain  Service  Agents (a  securities  dealer,
financial  institution or other industry  professional)  for  distributing  such
Fund's Class A shares and servicing shareholder  accounts,  and (b) paid Dreyfus
Service  Corporation or any affiliate for advertising and marketing  relating to
the Class A shares of such Fund and for shareholder servicing activities,  at an
aggregate  annual rate of .25 of 1% of the value of the average daily net assets
of Class A of such Fund.  During the six months ended  October 31, 2000,  $5,988
and $557 were  charged to the Class A shares of Capital  Value Fund and Strategy
Fund, respectively.

Under the Class B and Class C Service and Distribution  Plans,  the Company,  at
the expense of the Class B shares of the  Capital  Value Fund and Class C shares
of each Fund, as the case may be, (a) pays the Distributor for  distributing the
Capital  Value Fund's Class B shares and each Fund's Class C shares at an annual
rate of .75 of 1% of the value of the  average  daily  net  assets of Class B or
Class C of the applicable Fund and (b) pays the Distributor for the provision of
certain  services  to the  holders of Class B shares and Class C shares,  as the
case may be, a fee at the annual  rate of .25 of 1% of the value of the  average
daily net assets of Class B or Class C of such Fund. During the six months ended
October 31, 2000, $3,604 and $1,063 were charged for distributing  Capital Value
Fund's  Class B and  Class C  shares,  respectively,  and  $1,201  and $354 were
charged for  shareholder  servicing for Capital Value Fund's Class B and Class C
shares,  respectively.  For  the  same  period,  $92 and $31  were  charged  for
distributing and shareholder servicing,  respectively, for Strategy Fund's Class
C shares.




                                       14
                                     <PAGE>

COMSTOCK FUNDS, INC.
NOTES TO FINANCIAL STATEMENTS (CONTINUED) (UNAUDITED)
--------------------------------------------------------------------------------

5.  PORTFOLIO  SECURITIES:  Purchases and sales of securities for the six months
ended October 31, 2000, other than short-term securities, were as follows:

                                             PURCHASES             SALES
                                            -----------         -----------
Strategy Fund: .........................    $12,400,913         $17,178,397
                                            ===========         ===========
Capital Value Fund:
   Long transactions ...................    $        --         $   114,840
   Short sale transactions .............     11,047,043           6,302,188
                                            -----------         -----------
                                            $11,047,043         $ 6,417,028
                                            ===========         ===========

6. CAPITAL STOCK  TRANSACTIONS.  Transactions in shares of capital stock were as
follows:

<TABLE>
<CAPTION>
                                                                  STRATEGY FUND                CAPITAL VALUE FUND
                                                         ------------------------------ -------------------------------
                                                         SIX MONTHS ENDED               SIX MONTHS ENDED
                                                         OCTOBER 31, 2000  YEAR ENDED   OCTOBER 31, 2000   YEAR ENDED
                                                            (UNAUDITED)  APRIL 30, 2000    (UNAUDITED)   APRIL 30, 2000
                                                         --------------- -------------- ---------------- --------------
<S>                                                         <C>            <C>             <C>             <C>
         CLASS O:
Shares sold.........................................          43,707               --
Shares issued upon reinvestment of dividends........          34,672           94,459
Shares redeemed.....................................        (897,750)      (2,473,941)
                                                            --------       ----------
   Net decrease in Class O shares...................        (819,371)      (2,379,482)
                                                            ========       ==========
CLASS A:
Shares sold.........................................         134,729           97,794         838,110       9,753,239
Shares issued upon reinvestment of dividends........           5,851           21,364              --         167,904
Shares redeemed.....................................        (345,271)        (772,651)     (5,461,499)    (12,484,941)
                                                            --------       ----------      ----------     -----------
   Net decrease in Class A shares...................        (204,691)        (653,493)     (4,623,389)     (2,563,798)
                                                            ========       ==========      ==========     ===========
CLASS B:
Shares sold.........................................                                          547,840       1,464,663
Shares issued upon reinvestment of dividends........                                               --           2,321
Shares redeemed.....................................                                         (728,910)     (2,511,093)
                                                                                           ----------     -----------
   Net decrease in Class B shares...................                                         (181,070)     (1,044,109)
                                                                                           ==========     ===========
CLASS C:
Shares sold.........................................             222           89,073          27,919         756,546
Shares issued upon reinvestment of dividends........             318              951              --              --
Shares redeemed.....................................         (10,518)        (181,581)       (112,400)     (1,358,811)
                                                            --------       ----------      ----------     -----------
   Net decrease in Class C shares...................          (9,978)         (91,557)        (84,481)       (602,265)
                                                            ========       ==========      ==========     ===========

CLASS R:
Shares sold.........................................                                              217              --
Shares issued upon reinvestment of dividends........                                               --             115
Shares redeemed.....................................                                           (1,248)         (6,897)
                                                                                           ----------     -----------
   Net decrease in Class R shares...................                                           (1,031)         (6,782)
                                                                                           ==========     ===========
</TABLE>


                                       15
                                     <PAGE>

COMSTOCK FUNDS, INC.
NOTES TO FINANCIAL STATEMENTS (CONTINUED) (UNAUDITED)
--------------------------------------------------------------------------------

7. FEDERAL  INCOME TAX  INFORMATION.  The following  summarizes the capital loss
carryforwards of each Fund at April 30, 2000:

     EXPIRING IN FISCAL YEAR         STRATEGY FUND          CAPITAL VALUE FUND
     -----------------------         -------------          ------------------
             2001                     $ 8,777,000              $ 17,716,000
             2002                              --                56,799,000
             2003                              --                 9,145,000
             2004                      12,520,000                15,769,000
             2005                      14,913,000                14,169,000
             2006                      14,076,000                57,497,000
             2007                      26,320,000                48,938,000
             2008                      15,124,000                36,909,000
                                      -----------              ------------
                                      $91,730,000              $256,942,000
                                      ===========              ============

                                       16
                                     <PAGE>


COMSTOCK FUNDS, INC.
FINANCIAL HIGHLIGHTS
--------------------------------------------------------------------------------
Selected data for a share of capital stock outstanding throughout each period:

<TABLE>
<CAPTION>
                 INCOME FROM INVESTMENT OPERATIONS                       DISTRIBUTIONS
           -----------------------------------------------     ----------------------------------

                                      Net
           Net Asset             Realized and      Total                   Net                   Net Asset
  Period     Value,      Net      Unrealized       from         Net     Realized                   Value,
   Ended   Beginning  Investment Gain (Loss)on  Investment  Investment   Gain on        Total      End of   Total
 April 30  of Period  Income(b)   Investments   Operations    Income   Investments  Distributions  Period  Return(c)
 --------  ---------  ---------   -----------   ----------    ------   -----------  -------------  ------  ---------
<S>          <C>        <C>         <C>          <C>          <C>                      <C>         <C>       <C>
STRATEGY FUND
CLASS O
   2000 (a)  $4.04      $0.06       $(0.18)      $(0.12)      $(0.07)        --        $(0.07)     $3.85     (2.94)%
   2000       4.94       0.20        (0.90)       (0.70)       (0.20)        --         (0.20)      4.04    (14.35)
   1999       6.06       0.30        (0.94)       (0.64)       (0.48)        --         (0.48)      4.94    (11.32)
   1998       7.77       0.43        (1.54)       (1.11)       (0.60)        --         (0.60)      6.06    (14.88)
   1997       8.78       0.78        (1.19)       (0.41)       (0.47)     (0.13)        (0.60)      7.77     (4.85)
   1996       9.10       0.76        (0.53)        0.23        (0.55)        --         (0.55)      8.78      2.66

CLASS A
   2000 (a)   4.04       0.07        (0.19)       (0.12)       (0.07)        --         (0.07)      3.85     (3.06)
   2000       4.94       0.19        (0.90)       (0.71)       (0.19)        --         (0.19)      4.04    (14.58)
   1999       6.06       0.29        (0.95)       (0.66)       (0.46)        --         (0.46)      4.94    (11.56)
   1998       7.77       0.42        (1.55)       (1.13)       (0.58)        --         (0.58)      6.06    (15.11)
   1997       8.78       0.54        (0.96)       (0.42)       (0.46)     (0.13)        (0.59)      7.77     (5.10)
   1996       9.10       0.57        (0.36)        0.21        (0.53)        --         (0.53)      8.78      2.40

CLASS C
   2000 (a)   4.04       0.04        (0.16)       (0.12)       (0.05)        --         (0.05)      3.87     (3.44)
   2000       4.94       0.15        (0.90)       (0.75)       (0.15)        --         (0.15)      4.04    (14.89)
   1999       6.06       0.26        (0.97)       (0.71)       (0.41)        --         (0.41)      4.94    (12.42)
   1998       7.74       0.37        (1.54)       (1.17)       (0.51)        --         (0.51)      6.06    (15.61)
   1997       8.77       0.45        (0.95)       (0.50)       (0.41)     (0.12)        (0.53)      7.74     (5.94)
   1996+      9.00       0.37        (0.22)        0.15        (0.38)        --         (0.38)      8.77      1.96 (d)


<CAPTION>
                      RATIOS TO AVERAGE NET ASSETS/SUPPLEMENTAL DATA
           -------------------------------------------------------------------
                                                        Decrease
                             Net                      Reflected in
             Net Assets   Investment    Operating    Expense Ratios
  Period       End of     Income to    Expenses to       Due to      Portfolio
   Ended       Period      Average     Average Net   Administrative  Turnover
 April 30    (in 000's)   Net Assets     Assets        Fee Waiver      Rate
 --------    ----------   ----------     ------        ----------      ----
<S>            <C>           <C>          <C>              <C>              <C>
STRATEGY FUND
CLASS O
   2000 (a)    $23,426       3.23%(e)     2.28%(e)           --          44%
   2000         27,854       4.55         2.23               --         112
   1999         45,803       5.59         1.49             0.14%        130
   1998         71,692       6.01         1.31             0.01         227
   1997        134,719       6.80         1.18               --         126
   1996        224,148       6.56         1.23               --          96

CLASS A
   2000 (a)      2,826       2.98(e)      2.53(e)            --          44
   2000          3,789       4.28         2.46               --         112
   1999          7,858       5.05         1.75             0.14         130
   1998         17,871       5.79         1.55             0.01         227
   1997         43,327       6.55         1.43               --         126
   1996         53,652       6.33         1.48               --          96

CLASS C
   2000 (a)        164       2.23(e)      3.28(e)            --          44
   2000            212       3.51         3.16               --         112
   1999            710       4.14         2.48             0.14         130
   1998          1,780       5.08         2.29             0.01         227
   1997         13,020       5.81         2.14               --         126
   1996+           317       5.79(e)      2.28(e)            --          96
--------------------------------
<FN>
+   Class C shares were introduced on August 1, 1995. Except as indicated below,
    information is presented for the period from August 1, 1995 to April 30,
    1996.
(a) For the period ended October 31, 2000; unaudited.
(b) Based on average shares  outstanding.
(c) Total investment returns exclude the effects of sales loads and assume
    reinvestment of dividends and distributions.
(d) Total investment return is presented for the year ended April 30, 1996. For
    the period prior to August 1, 1995, total investment return is based upon
    the total investment return for Class A shares, and does not reflect the
    greater service and distribution fees and certain other expenses borne by
    Class C shares.
(e) Annualized.
</FN>
</TABLE>



                 See accompanying notes to financial statements.

                                       17
<PAGE>

COMSTOCK FUNDS, INC.
FINANCIAL HIGHLIGHTS (CONTINUED)

--------------------------------------------------------------------------------


Selected data for a share of capital stock outstanding throughout each period:

<TABLE>
<CAPTION>
                    INCOME FROM INVESTMENT OPERATIONS               DISTRIBUTIONS
             ------------------------------------------------  -----------------------


             Net Asset              Net Realized     Total                             Net Asset
  Period      Value,       Net     and Unrealized    from         Net                   Value,
   Ended    Beginning  Investment  Gain (Loss) on  Investment  Investment    Total      End of    Total
 April 30   of Period   Income(b)   Investmernts   Operations    Income  Distributions  Period  Return(c)
 --------   ---------   ---------   ------------   ----------    ------  -------------  ------  ---------
<S>           <C>        <C>          <C>            <C>         <C>        <C>          <C>     <C>
CAPITAL VALUE FUND
CLASS A
   2000 (a)   $2.72      $0.08        $(0.05)        $0.03           --         --       $2.75     1.10%
   2000        3.49       0.12         (0.84)        (0.72)      $(0.05)    $(0.05)       2.72   (20.70)
   1999        5.06       0.14         (1.40)        (1.26)       (0.31)     (0.31)       3.49   (25.80)
   1998        8.62       0.31         (2.91)        (2.60)       (0.96)     (0.96)       5.06   (31.48)
   1997       10.54       0.59         (1.92)        (1.33)       (0.59)     (0.59)       8.62   (12.97)
   1996       10.61       0.22          0.17          0.39        (0.46)     (0.46)      10.54     3.81

CLASS B
   2000 (a)    2.71       0.07         (0.04)         0.03           --         --        2.74     1.11
   2000        3.47       0.10         (0.86)        (0.76)          --**       --        2.71   (21.82)
   1999        4.99       0.11         (1.38)        (1.27)       (0.25)     (0.25)       3.47   (26.19)
   1998        8.45       0.25         (2.85)        (2.60)       (0.86)     (0.86)       4.99   (32.01)
   1997       10.38       0.54         (1.93)        (1.39)       (0.54)     (0.54)       8.45   (13.69)
   1996       10.41       0.18          0.16          0.34        (0.37)     (0.37)      10.38     3.36

CLASS C
   2000 (a)    2.61       0.07         (0.05)         0.02           --         --        2.63     0.77
   2000        3.32       0.09         (0.80)        (0.71)          --         --        2.61   (21.39)
   1999        4.80       0.10         (1.32)        (1.22)       (0.26)     (0.26)       3.32   (26.22)
   1998        8.31       0.23         (2.78)        (2.55)       (0.96)     (0.96)       4.80   (32.10)
   1997       10.24       0.57         (1.91)        (1.34)       (0.59)     (0.59)       8.31   (13.47)
   1996       10.41       0.44         (0.12)         0.32        (0.49)     (0.49)      10.24     3.30

CLASS R
   2000 (a)    2.71       0.09         (0.04)         0.05           --         --        2.76     1.85
   2000        3.48       0.14         (0.85)        (0.71)       (0.06)     (0.06)       2.71   (20.49)
   1999        5.05       0.15         (1.40)        (1.25)       (0.32)     (0.32)       3.48   (25.67)
   1998        8.62       0.33         (2.91)        (2.58)       (0.99)     (0.99)       5.05   (31.28)
   1997       10.53       0.82(b)      (2.13)        (1.31)       (0.60)     (0.60)       8.62   (12.83)
   1996       10.62       0.30          0.09          0.39        (0.48)     (0.48)      10.53     3.97


<CAPTION>
                   RATIOS TO AVERAGE NET ASSETS/SUPPLEMENTAL DATA
             ------------------------------------------------------------
                                                Interest Expense
                             Net                  and Dividends
             Net Assets    Investment  Operating   on Securities
  Period       End of     Income to  Expenses to   Sold Short   Portfolio
   Ended       Period      Average    Average to     Average    Turnover
 April 30    (in 000's)   Net Assets  Net Assets    Net Assets    Rate
 --------    ----------   ----------  ----------    ----------  ---------
<S>           <C>           <C>         <C>            <C>         <C>
CAPITAL VALUE FUND
CLASS A
   2000 (a)   $ 26,907      5.71%(e)    2.03%(e)       0.02%(e)      0%
   2000         39,112      3.82        2.01           0.28         --
   1999         59,246      3.31        1.47           0.72        465
   1998         64,452      4.49        1.35           0.24        359
   1997        160,834      6.16        1.28           0.51        399
   1996        241,472      2.13(d)     0.75           0.18(d)      56

CLASS B
   2000 (a)      7,516      4.96(e)     2.78(e)        0.02(e)      --
   2000          7,936      3.04        2.78           0.28         --
   1999         13,752      2.46        2.21           0.85        465
   1998         26,235      3.74        2.10           0.24        359
   1997         64,671      5.52        2.03           0.50        399
   1996         81,786      1.70(d)     1.18(d)        0.19(d)      56

CLASS C
   2000 (a)      2,167      4.96(e)     2.78(e)        0.02(e)      --
   2000          2,366      3.07        2.71           0.28         --
   1999          5,014      2.54        2.18           0.78        465
   1998          8,029      3.70        2.08           0.21        359
   1997          7,271      6.02        2.07           0.47        399
   1996          3,531      1.71(d)     1.28(d)        0.18(d)      56

CLASS R
   2000 (a)          2      5.96(e)     1.78(e)        0.02(e)      --
   2000              5      4.13        1.61           0.23         --
   1999             29      3.56        1.24           0.72        465
   1998             28      4.73        1.11           0.26        359
   1997            117      8.65        1.19           0.38        399
   1996              1      2.28(d)     0.61(d)        0.17(d)      56
--------------------------------
<FN>
(a) For ther period ended October 31,  2000; unaudited.
(b) Based on average shares outstanding.
(c) Total investment returns exclude the effects of sales loads and assume
    reinvestment of dividends and  distributions. Total investment  returns for
    periods of less than one full year are not annualized.
(d) Not annualized.
(e) Annualized.
**  Amount is less than $0.01 per share.
</FN>
</TABLE>

                See accompanying notes to financial statements.

                                       18
                                     <PAGE>

                             GABELLI FAMILY OF FUNDS

GABELLI ASSET FUND _____________________________________________________________
Seeks to invest primarily in a diversified portfolio of common stocks selling at
significant  discounts  to  their  private  market  value.  The  Fund's  primary
objective is growth of capital. (CLASS AAA-NO-LOAD)
                                        PORTFOLIO MANAGER: MARIO J. GABELLI, CFA

GABELLI GROWTH FUND ____________________________________________________________
Seeks to invest  primarily in large cap stocks believed to have  favorable,  yet
undervalued,  prospects for earnings  growth.  The Fund's  primary  objective is
capital appreciation.
(CLASS AAA-NO-LOAD)
                                          PORTFOLIO MANAGER: HOWARD F. WARD, CFA

GABELLI WESTWOOD EQUITY FUND ___________________________________________________
Seeks to invest primarily in the common stock of seasoned  companies believed to
have proven records and above average  historical  earnings  growth.  The Fund's
primary objective is capital appreciation. (MULTICLASS)
                                               PORTFOLIO MANAGER: SUSAN M. BYRNE

GABELLI BLUE CHIP VALUE FUND____________________________________________________
Seeks  long-term  growth of capital through  investment  primarily in the common
stocks  of   well-established,   high   quality   companies   that  have  market
capitalizations of greater than $5 billion. (CLASS AAA-NO-LOAD)
                                          PORTFOLIO MANAGER: BARBARA MARCIN, CFA

GABELLI SMALL CAP GROWTH FUND___________________________________________________
Seeks  to  invest  primarily  in  common  stock  of  smaller  companies  (market
capitalizations  less than $500  million)  believed  to have rapid  revenue  and
earnings growth potential. The Fund's primary objective is capital appreciation.
(CLASS AAA-NO-LOAD)
                                        PORTFOLIO MANAGER: MARIO J. GABELLI, CFA

GABELLI WESTWOOD SMALLCAP EQUITY FUND___________________________________________
Seeks to invest primarily in smaller  capitalization  equity securities - market
caps of $1 billion or less.  The Fund's primary  objective is long-term  capital
appreciation. (MULTICLASS)
                                            PORTFOLIO MANAGER: LYNDA CALKIN, CFA

GABELLI WESTWOOD INTERMEDIATE BOND FUND_________________________________________
Seeks to invest in a diversified portfolio of bonds with various maturities. The
Fund's primary objective is total return. (MULTICLASS)
                                               PORTFOLIO MANAGER: PATRICIA FRAZE

GABELLI EQUITY INCOME FUND______________________________________________________
Seeks to invest primarily in equity securities with above market average yields.
The Fund pays quarterly dividends and seeks a high level of total return with an
emphasis on income.
(CLASS AAA-NO-LOAD)
                                        PORTFOLIO MANAGER: MARIO J. GABELLI, CFA

GABELLI WESTWOOD BALANCED FUND__________________________________________________
Seeks to invest in a balanced and diversified portfolio of stocks and bonds. The
Fund's  primary  objective  is both  capital  appreciation  and current  income.
(MULTICLASS)
                             PORTFOLIO MANAGERS: SUSAN M. BYRNE & PATRICIA FRAZE

GABELLI WESTWOOD REALTY FUND____________________________________________________
Seeks to invest in securities  that are  primarily  engaged in or related to the
real  estate  industry.  The  Fund's  primary  objective  is  long-term  capital
appreciation. (CLASS AAA-NO-LOAD)
                                               PORTFOLIO MANAGER: SUSAN M. BYRNE

GABELLI WESTWOOD MIGHTY MITESSM FUND____________________________________________
Seeks to invest in micro-cap companies that have market  capitalizations of $300
million or less. The Fund's primary objective is long-term capital appreciation.
(MULTICLASS)
                                            TEAM MANAGED: MARIO J. GABELLI, CFA,
                           MARC J. GABELLI, LAURA K. LINEHAN AND WALTER K. WALSH
GABELLI VALUE FUND______________________________________________________________
Seeks to invest in  securities  of  companies  believed to be  undervalued.  The
Fund's primary objective is long-term capital appreciation. (MULTICLASS)
                                        PORTFOLIO MANAGER: MARIO J. GABELLI, CFA

GABELLI UTILITIES FUND__________________________________________________________
Seeks to provide a high level of total return  through a combination  of capital
appreciation and current income. (CLASS AAA-NO-LOAD)
                                         PORTFOLIO MANAGER: TIMOTHY O'BRIEN, CFA

GABELLI ABC FUND________________________________________________________________
Seeks to invest in securities with attractive  opportunities for appreciation or
investment  income.  The Fund's  primary  objective  is total  return in various
market conditions without excessive risk of capital loss. (NO-LOAD)
                                        PORTFOLIO MANAGER: MARIO J. GABELLI, CFA

GABELLI MATHERS FUND____________________________________________________________
Seeks  long-term  capital  appreciation  in various  market  conditions  without
excessive risk of capital loss. (CLASS AAA-NO-LOAD)
                                        PORTFOLIO MANAGER: HENRY VAN DER EB, CFA

GABELLI U.S. TREASURY MONEY MARKET FUND_________________________________________
Seeks to invest exclusively in short-term U.S. Treasury  securities.  The Fund's
primary  objective  is to  provide  high  current  income  consistent  with  the
preservation of principal and liquidity. (NO-LOAD)
                                             PORTFOLIO MANAGER: JUDITH A. RANERI

GABELLI CASH MANAGEMENT CLASS OF
THE TREASURER'S FUND____________________________________________________________
Three money market  portfolios  designed to generate  superior  returns  without
compromising  portfolio  safety.  U.S.  Treasury Money Market seeks to invest in
U.S. Treasury bills, notes and bonds. Tax Exempt Money Market seeks to invest in
municipal  securities.  Domestic  Prime  Money  Market  seeks to invest in prime
quality, domestic money market instruments. (NO-LOAD)
                                             PORTFOLIO MANAGER: JUDITH A. RANERI

AN INVESTMENT IN THE ABOVE MONEY MARKET FUNDS IS NEITHER  INSURED NOR GUARANTEED
BY THE FEDERAL DEPOSIT INSURANCE CORPORATION OR ANY GOVERNMENT AGENCY.  ALTHOUGH
THE FUNDS SEEK TO PRESERVE THE VALUE OF YOUR  INVESTMENT AT $1.00 PER SHARE,  IT
IS POSSIBLE TO LOSE MONEY BY INVESTING IN THE FUNDS. GLOBAL SERIES

  GABELLI GLOBAL TELECOMMUNICATIONS FUND
  Seeks  to  invest  in  telecommunications  companies  throughout  the  world -
  targeting  undervalued  companies with strong earnings and cash flow dynamics.
  The Fund's primary objective is capital appreciation. (MULTICLASS)
                                                                    TEAM MANAGED

  GABELLI GLOBAL CONVERTIBLE SECURITIES FUND
  Seeks  to  invest   principally  in  bonds  and  preferred  stocks  which  are
  convertible  into common stock of foreign and domestic  companies.  The Fund's
  primary  objective is total return through a combination of current income and
  capital appreciation. (MULTICLASS)
                                                                    TEAM MANAGED

  GABELLI GLOBAL GROWTH FUND
  Seeks capital appreciation  through a disciplined  investment program focusing
  on the globalization and  interactivity of the world's  marketplace.  The Fund
  invests in  companies  at the  forefront  of  accelerated  growth.  The Fund's
  primary objective is capital appreciation. (MULTICLASS)           TEAM MANAGED

  GABELLI GLOBAL OPPORTUNITY FUND
  Seeks to  invest in common  stock of  companies  which  have  rapid  growth in
  revenues and earnings and potential for above average capital  appreciation or
  are undervalued. The Fund's primary objective is capital appreciation.
  (MULTICLASS)                                                      TEAM MANAGED

GABELLI GOLD FUND_______________________________________________________________

Seeks to invest in a global  portfolio of equity  securities  of gold mining and
related  companies.  The Fund's  objective  is long-term  capital  appreciation.
Investment in gold stocks is considered speculative and is affected by a variety
of world-wide economic, financial and political factors. (CLASS AAA-NO-LOAD)
                                                 PORTFOLIO MANAGER: CAESAR BRYAN

GABELLI INTERNATIONAL GROWTH FUND_______________________________________________
Seeks to invest in the equity  securities  of  foreign  issuers  with  long-term
capital   appreciation    potential.    The   Fund   offers   investors   global
diversification. (MULTICLASS)
                                                 PORTFOLIO MANAGER: CAESAR BRYAN

THE SIX FUNDS  ABOVE  INVEST IN  FOREIGN  SECURITIES  WHICH  INVOLVES  RISKS NOT
ORDINARILY  ASSOCIATED WITH INVESTMENTS IN DOMESTIC ISSUES,  INCLUDING  CURRENCY
FLUCTUATION,   ECONOMIC  AND  POLITICAL   RISKS.  THE  FUNDS  LISTED  ABOVE  ARE
DISTRIBUTED BY GABELLI & COMPANY, INC.

COMSTOCK CAPITAL VALUE FUND_____________________________________________________
Seeks capital  appreciation and current income.  The Fund may use either long or
short positions to achieve its objective. (MULTICLASS)
                                           PORTFOLIO MANAGER: MARTIN WEINER, CFA

COMSTOCK STRATEGY FUND__________________________________________________________
The Fund emphasizes investments in debt securities,  which maximize total return
in light of credit risk,  interest rate risk, and the risk  associated  with the
length of maturity of the debt instrument. (MULTICLASS)
                                           PORTFOLIO MANAGER: MARTIN WEINER. CFA

--------------------------------------------------------------------------------
 TO RECEIVE A PROSPECTUS, CALL 1-800-GABELLI (422-3554). THE PROSPECTUS GIVES A
  MORE COMPLETE DESCRIPTION OF THE FUND, INCLUDING FEES AND EXPENSES. READ THE
             PROSPECTUS CAREFULLY BEFORE YOU INVEST OR SEND MONEY.

                              VISIT OUR WEBSITE AT:
                     WWW.GABELLI.COM OR, CALL: 1-800-GABELLI
         1-800-422-3554 [BULLET] 914-921-5100 [BULLET] FAX: 914-921-5118
                           [BULLET] [email protected]
                    ONE CORPORATE CENTER, RYE, NEW YORK 10580
                                     <PAGE>

                            THE COMSTOCK FUNDS, INC.
                             Comstock Strategy Fund
                           Comstock Capital Value Fund
                              One Corporate Center
                            Rye, New York 10580-1434
                                  1-800-GABELLI
                                [1-800-422-3554]
                               FAX: 1-914-921-5118
                             HTTP://WWW.GABELLI.COM
                            E-MAIL: [email protected]
                     (Net Asset Value may be obtained daily
                         by calling 1-800-GABELLI after
                                   6:00 P.M.)

                               BOARD OF DIRECTORS

          M. Bruce Adelberg               Werner J. Roeder, MD
          CONSULTANT                      MEDICAL DIRECTOR
          MBA RESEARCH GROUP              LAWRENCE HOSPITAL

          Anthony J. Colavita             Robert M. Smith
          ATTORNEY-AT-LAW                 PRESIDENT AND DIRECTOR
          ANTHONY J. COLAVITA, P.C.       SMITH ADVISORS, LTD.

          Vincent D. Enright              Henry G. Van der Eb
          FORMER SENIOR VICE PRESIDENT    CHAIRMAN
          AND CHIEF FINANCIAL OFFICER,    THE COMSTOCK FUNDS, INC.
          KEYSPAN ENERGY CORP.

          Charles L. Minter               Anthony R. Pustorino
          FORMER CHAIRMAN AND             CERTIFIED PUBLIC ACCOUNTANT
          CHIEF EXECUTIVE OFFICER         PROFESSOR, PACE UNIVERSITY
          COMSTOCK PARTNERS, INC.

                                    OFFICERS

          Henry G. Van der Eb             Martin Weiner, CFA
          CHAIRMAN                        PORTFOLIO MANAGER
                                          AND PRESIDENT

          Bruce N. Alpert                 Charles L. Minter
          EXECUTIVE VICE PRESIDENT        PORTFOLIO MANAGER
          AND TREASURER                   AND DIRECTOR

          James E. McKee                  Carolyn Matlin
          SECRETARY                       VICE PRESIDENT

          Gus Coutsouros
          VICE PRESIDENT

                                   DISTRIBUTOR
                             Gabelli & Company, Inc.

                  TRANSFER AGENT AND DIVIDEND DISBURSING AGENT
                       State Street Bank and Trust Company

                                  LEGAL COUNSEL
                    Skadden, Arps, Slate, Meagher & Flom LLP

--------------------------------------------------------------------------------
This report is not authorized  for use in connection  with an offer of sale or a
solicitation of an offer to buy shares of a Fund unless  accompanied or preceded
by a Fund's current  prospectus.  Past performance  results shown in this report
should not be  considered a  representation  of future  performance.  Investment
return  and  principal  value of shares  will  fluctuate  so that  shares,  when
redeemed, may be worth more or less than their original cost.
--------------------------------------------------------------------------------
GABCOMSA00SR


THE
COMSTOCK
FUNDS,
INC.

Comstock Capital Value Fund
Comstock Strategy Fund


                                                              SEMI-ANNUAL REPORT
                                                                OCTOBER 31, 2000


© 2022 IncJournal is not affiliated with or endorsed by the U.S. Securities and Exchange Commission