Statement of Additional Info - Gabelli

test, at the close of each quarter of a Fund’s taxable year, at least 50% of the value of that Fund’s assets must consist of
cash and cash items, U.S. Government securities, securities of other regulated investment companies, and securities of
other issuers (as to which the Fund has not invested more than 5% of the value of the Fund’s total assets in securities of
such issuer and as to which the Fund does not hold more than 10% of the outstanding voting securities of such issuer),
and no more than 25% of the value of its total assets may be invested in the securities of any one issuer (other than U.S.
Government securities and securities of other regulated investment companies), in two or more issuers which that Fund
controls (by owning 20% or more of the outstanding voting securities of such issuer) and which are engaged in the same
or similar trades or businesses, or in the securities of qualified publicly traded partnerships. Generally, an option (call or
put) with respect to a security is treated as issued by the issuer of the security, not the issuer of the option.
In addition to satisfying the requirements described above, a regulated investment company must derive at least 90% of
its gross income from dividends, interest, certain payments with respect to securities loans, gains from the sale or other
disposition of stock or securities or foreign currencies, other income (including but not limited to gains from options,
futures, or forward contracts) derived with respect to its business of investing in such stock, securities, or currencies and
net income from qualified publicly traded partnerships.
If, for any taxable year, a Fund does not qualify as a regulated investment company, all of its taxable income would be
subject to tax at regular corporate rates without any deduction for distributions to shareholders, and any distributions
would be taxable to the shareholders as ordinary dividends to the extent of the Fund’s current or accumulated earnings
and profits.
Excise Tax on Regulated Investment Companies
Amounts, other than tax exempt interest, not distributed on a timely basis may be subject to a nondeductible 4% excise
tax. To prevent imposition of the excise tax, the Funds must distribute during the calendar year an amount equal to the
sum of (1) at least 98% of their ordinary income (excluding any capital gains or losses) for the calendar year, (2) at least
98.2% of the excess of their capital gains over capital losses (adjusted for certain losses) for the one-year period ending
October 31 of such year (or, at the election of a regulated investment company having a taxable year ending November
30 or December 31, for its taxable year), and (3) any deficiencies from distributions in such prior years.
Fund Distributions
Each Fund’s policy is to declare dividends annually, except for the Balanced and Income Funds, which declare dividends
quarterly, and the Intermediate Bond Fund, which declares dividends daily and pays them monthly. Each Fund
distributes all or substantially all (and in no event less than 90%) of its investment company taxable income each year.
Distributions of investment company taxable income, including net short term capital gains, generally are taxable to
shareholders as ordinary income. Distributions of net long term capital gains, if any, reported by the Funds as capital
gain dividends are taxable to shareholders as long term capital gains, regardless of the length of time the shareholder has
held its shares of a Fund. In determining the amount of net capital gains to be distributed, any capital loss carryover from
prior years will be applied against capital gains to reduce the amount of distributions paid. Shareholders will be notified
annually as to the U.S. federal tax status of distributions.
If any net capital gains are retained by the Funds for reinvestment, requiring federal income taxes thereon to be paid by it,
the Funds can elect to treat such capital gains as having been distributed to shareholders. In that event, shareholders will
report such capital gains as net capital gains, will be able to claim their share of federal income taxes paid by a Fund on
such gains as a credit against their own federal income tax liability, and will be entitled to increase the adjusted tax basis
of their Fund shares by an amount equal to the difference between the amount of undistributed capital gains included in
their gross income and the tax deemed paid.
Distributions by a Fund that do not constitute ordinary income dividends or capital gain dividends will be treated as a
return of capital to the extent of (and in reduction of) the shareholder’s tax basis in its shares; any excess will be treated
as gain from the sale of its shares, as discussed below.
Dividends of investment company taxable income paid by the Fund will qualify for the 70% dividends-received
deduction generally available to corporate shareholders (other than certain corporations, such as S corporations, which
are not eligible for the deduction because of their special characteristics and other than for purposes of special taxes such
as the accumulated earnings tax and the personal holding company tax) to the extent of the amount of qualifying
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