UNITED STATES
                       SECURITIES AND EXCHANGE COMMISSION
                             Washington, D.C. 20549

                                   FORM N-CSR

   CERTIFIED SHAREHOLDER REPORT OF REGISTERED MANAGEMENT INVESTMENT COMPANIES

                  Investment Company Act file number 811-07326
                                                     ---------

                              The Gabelli ABC Fund
        -----------------------------------------------------------------
               (Exact name of registrant as specified in charter)

                              One Corporate Center
                            Rye, New York 10580-1422
        -----------------------------------------------------------------
               (Address of principal executive offices) (Zip code)

                                 Bruce N. Alpert
                               Gabelli Funds, LLC
                              One Corporate Center
                            Rye, New York 10580-1422
        -----------------------------------------------------------------
                     (Name and address of agent for service)

       registrant's telephone number, including area code: 1-800-422-3554
                                                           --------------

                      Date of fiscal year end: December 31
                                               -----------

                   Date of reporting period: December 31, 2003
                                             -----------------



Form N-CSR is to be used by management investment companies to file reports with
the Commission not later than 10 days after the transmission to stockholders of
any report that is required to be transmitted to stockholders under Rule 30e-1
under the Investment Company Act of 1940 (17 CFR 270.30e-1). The Commission may
use the information provided on Form N-CSR in its regulatory, disclosure review,
inspection, and policymaking roles.

A registrant is required to disclose the information specified by Form N-CSR,
and the Commission will make this information public. A registrant is not
required to respond to the collection of information contained in Form N-CSR
unless the Form displays a currently valid Office of Management and Budget
("OMB") control number. Please direct comments concerning the accuracy of the
information collection burden estimate and any suggestions for reducing the
burden to Secretary, Securities and Exchange Commission, 450 Fifth Street, NW,
Washington, DC 20549-0609. The OMB has reviewed this collection of information
under the clearance requirements of 44 U.S.C. ss. 3507.





ITEM 1. REPORTS TO STOCKHOLDERS.

The Annual Report to Shareholders is attached herewith.

                              THE GABELLI ABC FUND

                                  ANNUAL REPORT
                                DECEMBER 31, 2003



TO OUR SHAREHOLDERS,

      The Sarbanes-Oxley Act requires a Fund's principal executive and financial
officers  to  certify  the  entire   contents  of  the  semi-annual  and  annual
shareholder  reports in a filing with the Securities and Exchange  Commission on
Form N-CSR. This certification  would cover the portfolio  manager's  commentary
and  subjective  opinions  if they are  attached  to or a part of the  financial
statements. Many of these comments and opinions would be difficult or impossible
to certify.

      Because we do not want our portfolio  managers to eliminate their opinions
and/or  restrict their  commentary to historical  facts, we have separated their
commentary from the financial  statements and investment portfolio and have sent
it to  you  separately.  Both  the  commentary  and  the  financial  statements,
including  the  portfolio  of  investments,  will be available on our website at
www.gabelli.com/funds.

      Enclosed are the audited financial statements and the investment portfolio
as of  December  31,  2003 with a  description  of  factors  that  affected  the
performance during the past year.

PERFORMANCE DISCUSSION

      The Gabelli ABC Fund (the "Fund") was created for  conservative  investors
desiring to participate in the equity markets without  assuming the full risk of
portfolios  fully  invested in equities.  Our  objective is to achieve  positive
returns in the various  market  environments.  Our  approach to this mandate has
been to build a diversified  portfolio consisting of undervalued stocks,  stable
risk arbitrage  positions,  and risk-free  short-term U.S. Treasury  securities.
Throughout  the Fund's  history,  this  portfolio  mix has produced  respectable
returns in up markets and preserved capital during down markets. The Fund closed
2003 with a 4.9% gain, and has had positive total returns in each of the last 10
calendar years.

      After a deal-making  drought,  the pace of merger and acquisition activity
rebounded in 2003. During 2003, our Fund's top performers  included  PeopleSoft,
Titan Corp., Dana Corp. and Harbor Global.  Completed deals during the year that
boosted Fund performance included Wella AG, Scios, Banyu Pharmaceutical, Chateau
Communities,  J.D.  Edwards and  Pechiney.  Lagging  performers  during the year
included Griffin Land & Nurseries and BayCorp Holdings.

      As of April 1, 2002,  we lowered  our fees to 50 basis  points  because we
were sitting on an  above-average  amount of cash in the  portfolio due to a low
level of merger and acquisition  activity.  Furthermore,  as of January 1, 2003,
the distributor has voluntarily waived receipt of the 25 basis points Rule 12b-1
distribution fee from the Fund,  resulting in a waiver of fees totaling 75 basis
points.

                                Sincerely yours,

                                /s/Bruce N. Alpert
                                Bruce N. Alpert
                                President
February 24, 2004





[GRAPHIC OMITTED]
PLOT POINTS FOLLOW:

 COMPARISON OF CHANGE IN VALUE OF A $10,000 INVESTMENT IN THE GABELLI ABC FUND,
      THE LIPPER U.S. TREASURY MONEY MARKET AVERAGE AND THE S&P 500 INDEX

                                           Lipper U.S. Treasury
                   Gabelli ABC Fund        Money Market       S&P 500 Index
5/14/93            10,000                  10,000             10,000
12/93              10,910                  10,163             10,659
12/94              11,401                  10,530             10,798
12/95              12,278                  11,091             14,858
12/96              13,667                  11,618             18,275
12/97              15,410                  12,139             24,370
12/98              17,127                  12,706             31,374
12/99              18,668                  13,247             37,972
12/00              20,693                  13,981             34,517
12/01              21,637                  14,451             30,413
12/02              21,825                  14,600             23,695
Dec-03             22,903                  14,661             30,488

PAST PERFORMANCE IS NOT PREDICTIVE OF FUTURE RESULTS. The performance tables
and graph do not reflect the deduction of taxes that a shareholder would
pay on fund distributions or the redemption of fund shares.

COMPARATIVE RESULTS
- --------------------------------------------------------------------------------
              AVERAGE ANNUAL RETURNS THROUGH DECEMBER 31, 2003 (A)


                                                                                                          SINCE
                                                QUARTER    1 YEAR      3 YEAR     5 YEAR     10 YEAR  INCEPTION (B)
                                                -------    ------      ------     ------     -------  -------------
                                                                                      
 Gabelli ABC Fund .........................      1.98%      4.94%      3.44%       5.99%      7.70%      8.10%

 S&P 500 Index ............................     12.17%     28.67%     (4.05)%     (0.57)%    11.06%     11.19%
 Lipper U.S. Treasury Money
    Market Avg. ...........................      0.08%      0.42%      1.60%       2.91%      3.78%      3.71%(c)


 (a) Returns  represent past  performance  and do not guarantee  future results.
     Total returns and average annual returns reflect changes in share price and
     reinvestment  of dividends and capital gains  distributions  and are net of
     expenses.  Investment returns and the principal value of an investment will
     fluctuate.  When shares are  redeemed,  they may be worth more or less than
     their original  cost. The S&P 500 Index is an unmanaged  indicator of stock
     market   performance,   while  the  Lipper  Average  reflects  the  average
     performance  of  mutual  funds  classified  in  this  particular  category.
     Performance for periods less than one year is not annualized.
 (b) From commencement of investment operations on May 14, 1993.
 (c) From April 30,  1993,  the date closest to the Fund's  inception  for which
     data is available.
- --------------------------------------------------------------------------------
                                        2
                                     


THE GABELLI ABC FUND
PORTFOLIO OF INVESTMENTS -- DECEMBER 31, 2003
- --------------------------------------------------------------------------------
                                                                      MARKET
    SHARES                                              COST           VALUE
   -------                                              ----           -----
              COMMON STOCKS -- 25.1%
              AEROSPACE -- 2.6%
    350,000   Titan Corp.+ ......................   $  7,476,598   $  7,633,500
                                                    ------------   ------------
              AUTOMOTIVE: PARTS AND ACCESSORIES -- 0.8%
    125,000   Dana Corp. ........................      1,990,644      2,293,750
      5,000   Federal-Mogul Corp.+ ..............         14,938          1,125
                                                    ------------   ------------
                                                       2,005,582      2,294,875
                                                    ------------   ------------
              AVIATION: PARTS AND SERVICES -- 0.1%
      2,000   Aviall Inc.+ ......................         14,216         31,020
     20,000   Fairchild Corp., Cl. A+ ...........        157,951        100,800
     18,000   Kaman Corp., Cl. A ................        322,618        229,140
                                                    ------------   ------------
                                                         494,785        360,960
                                                    ------------   ------------
              BROADCASTING -- 0.1%
      4,000   Liberty Corp. .....................        175,808        180,760
        800   Salem Communications Corp.,
                Cl. A+ ..........................          6,232         21,696
                                                    ------------   ------------
                                                         182,040        202,456
                                                    ------------   ------------
              BUSINESS SERVICES -- 0.0%
      2,580   ProcureNet Inc.+ (a) ..............              0            387
                                                    ------------   ------------
              COMPUTER SOFTWARE AND SERVICES -- 0.3%
     40,000   PeopleSoft Inc.+ ..................        716,800        912,000
  1,215,000   StorageNetworks Inc.
                Escrow+ (a) .....................              0         36,450
                                                    ------------   ------------
                                                         716,800        948,450
                                                    ------------   ------------
              CONSUMER PRODUCTS -- 3.6%
    350,000   Dial Corp. ........................      9,961,725      9,964,500
     60,000   Levcor International Inc.+ ........        140,640        240,000
     40,000   Packaging Dynamics Corp. ..........        261,828        411,200
                                                    ------------   ------------
                                                      10,364,193     10,615,700
                                                    ------------   ------------
              DIVERSIFIED INDUSTRIAL -- 0.2%
      6,000   Ampco-Pittsburgh Corp. ............         69,606         82,020
     45,120   Harbor Global Co. Ltd.+ ...........        175,722        410,592
      4,000   Katy Industries Inc.+ .............         41,365         22,840
                                                    ------------   ------------
                                                         286,693        515,452
                                                    ------------   ------------
              ENERGY AND UTILITIES -- 2.1%
      5,000   BayCorp Holdings Ltd.+ ............         73,579         65,300
     20,000   NiSource Inc.+ ....................         40,000         51,200
     35,000   Northeast Utilities ...............        695,575        705,950
     25,000   Progress Energy Inc., CVO+ ........         13,000          5,750
      7,000   SJW Corp. .........................        666,802        624,750
      1,500   Southwest Gas Corp. ...............         26,231         33,675
    200,000   Unisource Energy Corp. ............      4,918,210      4,932,000
                                                    ------------   ------------
                                                       6,433,397      6,418,625
                                                    ------------   ------------

                                                                      MARKET
    SHARES                                              COST           VALUE
   -------                                              ----           -----
              ENTERTAINMENT -- 0.3%
    150,000   CINAR Corp., Cl. B+ ...............   $    532,245   $    541,500
     25,000   GC Companies Inc.+ ................          3,750          8,750
     15,000   Liberty Media Corp., Cl. A+ .......        157,955        178,350
                                                    ------------   ------------
                                                         693,950        728,600
                                                    ------------   ------------
              EQUIPMENT AND SUPPLIES -- 0.1%
     10,674   Juno Lighting Inc.+ ...............        157,139        240,165
                                                    ------------   ------------
              FINANCIAL SERVICES -- 1.7%
      5,000   Abington Bancorp Inc. .............        166,282        192,950
     24,000   Argonaut Group Inc.+ ..............        624,709        372,960
     83,900   Bank of Bermuda Ltd. ..............      3,774,040      3,771,305
      1,000   Coastal Bancorp Inc. ..............         41,250         41,110
     30,000   Concord EFS Inc.+ .................        316,179        445,200
      5,000   FleetBoston Financial Corp. .......        198,780        218,250
      1,000   Leucadia National Corp. ...........         30,175         46,100
      1,000   Republic Bancshares Inc. ..........         31,750         31,470
                                                    ------------   ------------
                                                       5,183,165      5,119,345
                                                    ------------   ------------
              FOOD AND BEVERAGE -- 6.6%
     20,000   Denny's Corp.+ ....................         49,969          8,200
    180,000   Dreyer's Grand Ice Cream
                Holdings Inc., Cl. A ............     13,924,491     13,995,000
        500   Genesee Corp., Cl. A+ .............          1,500          1,850
     12,200   Genesee Corp., Cl. B+ .............          7,936         44,042
    142,100   Grupo Continental SA ..............        218,331        240,263
    211,900   Horizon Organic Holding
                Corp.+ ..........................      5,043,213      5,075,005
                                                    ------------   ------------
                                                      19,245,440     19,364,360
                                                    ------------   ------------
              HEALTH CARE -- 5.0%
     60,000   BioReliance Corp.+ ................      2,873,793      2,869,200
    200,000   Esperion Therapeutics Inc.+ .......      6,912,555      6,922,000
    300,000   I-STAT Corp.+ .....................      4,578,755      4,590,000
      2,501   Zimmer Holdings Inc.+ .............        135,038        176,049
                                                    ------------   ------------
                                                      14,500,141     14,557,249
                                                    ------------   ------------
              METALS AND MINING -- 0.8%
     50,001   Alcan Inc. ........................      2,190,022      2,347,524
     10,000   Royal Oak Mines Inc.+ .............         11,858             45
                                                    ------------   ------------
                                                       2,201,880      2,347,569
                                                    ------------   ------------
              PAPER AND FOREST PRODUCTS -- 0.4%
     35,001   Boise Cascade Corp. ...............      1,048,265      1,150,117
                                                    ------------   ------------
              REAL ESTATE -- 0.1%
     20,000   Griffin Land & Nurseries Inc.+ ....        322,381        284,220
        316   HomeFed Corp.+ ....................            566          9,164
      1,000   ProLogis ..........................         22,650         32,090
                                                    ------------   ------------
                                                         345,597        325,474
                                                    ------------   ------------
              RETAIL -- 0.3%
      1,000   Duane Reade Inc.+ .................         16,760         16,920
     10,000   Gucci Group NV, ADR ...............        849,843        855,500
                                                    ------------   ------------
                                                         866,603        872,420
                                                    ------------   ------------


                 See accompanying notes to financial statements.


                                        3
                                     


THE GABELLI ABC FUND
PORTFOLIO OF INVESTMENTS (CONTINUED) -- DECEMBER 31, 2003
- --------------------------------------------------------------------------------
                                                                      MARKET
    SHARES                                              COST           VALUE
   -------                                              ----           -----
              COMMON STOCKS (CONTINUED)
              TELECOMMUNICATIONS -- 0.0%
     10,141   ATX Communications Inc.+ ..........   $     17,960   $      2,231
      3,000   Telegroup Inc.+ ...................             31              0
     10,000   USN Communications Inc.+ (a) ......            150             10
                                                    ------------   ------------
                                                          18,141          2,241
                                                    ------------   ------------
              WIRELESS COMMUNICATIONS-- 0.0%
        500   American Tower Corp., Cl. A+ ......          7,707          5,410
     14,000   Metricom Inc.+ ....................          1,680            112
     50,000   Winstar Communications Inc.+ ......          2,125             50
                                                    ------------   ------------
                                                          11,512          5,572
                                                    ------------   ------------
              TOTAL COMMON STOCKS ...............     72,231,921     73,703,517
                                                    ------------   ------------
              PREFERRED STOCKS -- 0.6%
              BROADCASTING -- 0.2%
      1,063   Granite Broadcasting Corp.,
                12.750% Pfd.+ ...................        439,685        680,320
                                                    ------------   ------------
              COMMUNICATIONS EQUIPMENT -- 0.0%
              RSL Communications Ltd.,
      1,000     7.500% Cv. Pfd. + (b)(c) ........             92              0
      2,000     7.500% Cv. Pfd., Ser. A + (c) ...            185              0
                                                    ------------   ------------
                                                             277              0
                                                    ------------   ------------
              DIVERSIFIED INDUSTRIAL -- 0.1%
              WHX Corp.,
     24,000     6.500% Cv. Pfd., Ser. A+ ........        413,792        118,800
     24,000     $3.75 Cv. Pfd., Ser. B+ .........        251,690        115,200
                                                    ------------   ------------
                                                         665,482        234,000
                                                    ------------   ------------
              HOME FURNISHINGS -- 0.0%
      8,000   O'Sullivan Industries Holdings Inc.,
                12.000% Pfd.+ ...................          4,750          2,560
                                                    ------------   ------------
              TELECOMMUNICATIONS -- 0.3%
     18,000   Citizens Communications Co.,
                5.000% Cv. Pfd. .................        922,290        918,000
                                                    ------------   ------------
              TOTAL PREFERRED STOCKS ............      2,032,484      1,834,880
                                                    ------------   ------------
   PRINCIPAL
    AMOUNT
    ------
              CORPORATE BONDS -- 0.6%
              COMPUTER SOFTWARE AND SERVICES -- 0.0%
 $  100,000   Exodus Communications Inc.,
                Sub. Deb. Cv.,
                5.250%, 02/15/08+ (c) ...........          2,250            375
                                                    ------------   ------------
              CONSUMER PRODUCTS -- 0.0%
    200,000   Revlon Consumer Products,
                Sub. Deb.,
                8.625%, 02/01/08 ................        114,982         87,000
                                                    ------------   ------------
              DIVERSIFIED INDUSTRIAL -- 0.4%
  1,500,000   GP Strategies Corp., Sub. Deb.,
                6.000%, 08/14/08 (a) ............      1,047,342      1,036,680
                                                    ------------   ------------
              ELECTRONICS -- 0.1%
    400,000   Oak Industries Inc.,
                Sub. Deb. Cv.,
                4.875%, 03/01/08 ................        324,803        399,500
                                                    ------------   ------------
 PRINCIPAL                                                           MARKET
   AMOUNT                                              COST           VALUE
   -------                                             ----           -----
              ENERGY AND UTILITIES-- 0.1%
 $  300,000   Mirant Corp., Sub. Deb. Cv.,
                2.500%, 06/15/21+ (c) ...........   $    226,624   $    184,500
                                                    ------------   ------------
              RETAIL -- 0.0%
    200,000  RDM Sports Group Inc.,
                Sub. Deb.,
                8.000%, 08/15/03+ (a)(c) ........          4,000         20,500
                                                    ------------   ------------
              TRANSPORTATION -- 0.0%
    850,000   Builders Transport Inc.,
                Sub. Deb. Cv.,
                6.500%, 05/01/11+ (a)(c) ........          8,500              0
                                                    ------------   ------------
              TOTAL CORPORATE BONDS .............      1,728,501      1,728,555
                                                    ------------   ------------
              U.S.  GOVERNMENT  OBLIGATIONS -- 73.5%
216,381,000   U.S.  Treasury Bills,
                0.842% to 0.945%++,
                01/02/04 to 03/25/04 ............    216,266,696    216,267,071
                                                    ------------   ------------
    SHARES
    ------
              WARRANTS -- 0.2%
              CONSUMER PRODUCTS -- 0.0%
     10,396   Pillowtex Corp.,
                expire 11/24/09+ ................         45,461              1
                                                    ------------   ------------
              DIVERSIFIED INDUSTRIAL -- 0.2%
    187,500   GP Strategies Corp.,
                expire 08/14/08+ (a) ............        477,799        477,799
                                                    ------------   ------------
              TOTAL WARRANTS ....................        523,260        477,800
                                                    ------------   ------------
              TOTAL INVESTMENTS --
                100.0% ..........................   $292,782,862    294,011,823
                                                                   ============
              OTHER ASSETS AND LIABILITIES (NET) -- 0.0%                 58,473
                                                                   ------------
              NET ASSETS -- 100.0% ..........................      $294,070,296
                                                                   ============
- ----------------
              For Federal tax purposes:
              Aggregate cost ................................      $292,661,488
                                                                   ============
              Gross unrealized appreciation .................      $  2,538,806
              Gross unrealized depreciation .................        (1,188,471)
                                                                   ------------
              Net unrealized appreciation/(depreciation) ....      $  1,350,335
                                                                   ============
- ----------------
(a)    Security fair valued under procedures established by the Board of
       Directors. At December 31, 2003, the market value of fair valued
       securities amounted to $1,571,826 or 0.5% of total net assets.
(b)    Security exempt from registration under Rule 144A of the Securities Act
       of 1933, as amended. These securities may be resold in transactions
       exempt from registration, normally to qualified institutional buyers. At
       December 31, 2003, the market value of Rule 144A securities amounted to
       $0 or 0.0% of total net assets.
(c)    Security in default.
 +     Non-income producing security.
 ++    Represents annualized yield at date of purchase.
 ADR - American Depository Receipt.
 CVO - Contingent Value Obligation.

                 See accompanying notes to financial statements.


                                        4
                                     


                              THE GABELLI ABC FUND

STATEMENT OF ASSETS AND LIABILITIES
DECEMBER 31, 2003
- --------------------------------------------------------------------------------
ASSETS:
  Investments, at value
    (Cost $292,782,862) ..................   $294,011,823
  Cash ...................................        268,911
  Dividends, reclaims and interest
    receivable ...........................         89,119
  Receivable for investments sold ........        898,941
  Receivable for Fund shares sold ........      1,688,274
  Other assets ...........................         15,136
                                             ------------
  TOTAL ASSETS ...........................    296,972,204
                                             ------------
LIABILITIES:
  Payable for investments purchased ......      2,494,140
  Payable for investment advisory fees ...        126,661
  Payable for Fund shares redeemed .......        128,098
  Other accrued expenses .................        153,009
                                             ------------
  TOTAL LIABILITIES ......................      2,901,908
                                             ------------
  NET ASSETS applicable to 29,906,505
    shares outstanding ...................   $294,070,296
                                             ============
NET ASSETS CONSIST OF:
  Capital stock, at par value ............   $     29,906
  Additional paid-in capital .............    292,790,776
  Accumulated net investment income ......        433,994
  Accumulated net realized loss
    on investments .......................       (413,773)
  Net unrealized appreciation
    on investments .......................      1,229,393
                                             ------------
  TOTAL NET ASSETS .......................   $294,070,296
                                             ============
  NET ASSET VALUE, offering and redemption price
    per share ($294,070,296 / 29,906,505
    shares outstanding; 1,000,000,000 shares
    authorized of $0.001 par value) ......          $9.83
                                                    =====


STATEMENT OF OPERATIONS
FOR THE YEAR ENDED DECEMBER 31, 2003
- --------------------------------------------------------------------------------
INVESTMENT INCOME:
  Dividends (net of foreign taxes
    of $38,911) ..........................    $   906,441
  Interest ...............................      2,455,658
                                              -----------
  TOTAL INVESTMENT INCOME ................      3,362,099
                                              -----------
EXPENSES:
  Investment advisory fees ...............      2,719,620
  Distribution fees ......................        679,861
  Custodian fees .........................        103,568
  Shareholder services fees ..............         96,430
  Shareholder communications expenses ....         67,863
  Legal and audit fees ...................         42,179
  Registration fees ......................         22,671
  Directors' fees ........................         11,053
  Miscellaneous expenses .................         57,249
                                              -----------
  TOTAL EXPENSES .........................      3,800,494
                                              -----------
  Fees waived ............................     (2,039,671)
                                              -----------
  TOTAL NET EXPENSES .....................      1,760,823
                                              -----------
  NET INVESTMENT INCOME ..................      1,601,276
                                              -----------
NET REALIZED AND UNREALIZED GAIN
  ON INVESTMENTS, FOREIGN CURRENCY
  AND FUTURES TRANSACTIONS:
  Net realized gain on investments,
    foreign currency and futures
    transactions .........................      6,845,476
  Net change in unrealized appreciation/
    depreciation on investments and
    foreign currency .....................      4,808,623
                                              -----------
  NET REALIZED AND UNREALIZED GAIN ON
    INVESTMENTS, FOREIGN CURRENCY
    AND FUTURES TRANSACTIONS .............     11,654,099
                                              -----------
  NET INCREASE IN NET ASSETS RESULTING
    FROM OPERATIONS ......................    $13,255,375
                                              ===========


STATEMENT OF CHANGES IN NET ASSETS
- --------------------------------------------------------------------------------


                                                                                 YEAR ENDED          YEAR ENDED
                                                                             DECEMBER 31, 2003   DECEMBER 31, 2002
                                                                             -----------------   -----------------
                                                                                              
OPERATIONS:
  Net investment income ....................................................    $  1,601,276         $ 1,918,519
  Net realized gain on investments, foreign currency, options
    and futures transactions ...............................................       6,845,476           1,340,955
  Net change in unrealized appreciation/depreciation on
    investments and foreign currency .......................................       4,808,623          (1,021,955)
                                                                                ------------        ------------
  NET INCREASE IN NET ASSETS RESULTING FROM OPERATIONS .....................      13,255,375           2,237,519
                                                                                ------------        ------------
DISTRIBUTIONS TO SHAREHOLDERS:
  Net investment income ....................................................        (302,802)         (1,365,987)
  Net realized gain on investments .........................................      (8,024,250)         (1,181,891)
                                                                                ------------        ------------
  TOTAL DISTRIBUTIONS TO SHAREHOLDERS ......................................      (8,327,052)         (2,547,878)
                                                                                ------------        ------------
CAPITAL SHARE TRANSACTIONS:
  Net increase in net assets from capital share transactions ...............      28,127,775          93,915,547
                                                                                ------------        ------------
  NET INCREASE IN NET ASSETS ...............................................      33,056,098          93,605,188
NET ASSETS:
  Beginning of period ......................................................     261,014,198         167,409,010
                                                                                ------------        ------------
  End of period ............................................................    $294,070,296        $261,014,198
                                                                                ============        ============



                 See accompanying notes to financial statements.


                                        5
                                     


THE GABELLI ABC FUND
NOTES TO FINANCIAL STATEMENTS
- --------------------------------------------------------------------------------
1. ORGANIZATION. The Gabelli ABC Fund (the "Fund"), a series of Gabelli Investor
Funds, Inc. (the "Corporation"), was organized on October 30, 1992 as a Maryland
corporation.  The  Fund is a  non-diversified,  open-end  management  investment
company  registered  under the  Investment  Company Act of 1940, as amended (the
"1940 Act").  The Fund's primary  objective is to achieve total returns that are
attractive to investors in various market  conditions  without excessive risk of
capital loss. The Fund commenced investment operations on May 14, 1993.

2. SIGNIFICANT  ACCOUNTING POLICIES.  The preparation of financial statements in
accordance with accounting  principles  generally  accepted in the United States
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 or traded in the U.S. over-the-counter market for
which market quotations are readily available are valued at the last quoted sale
price or a market's  official  closing  price 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. If no bid or asked  prices are quoted on such
day,  the  security is valued at the most  recently  available  price or, if the
Board of Directors so determines, by such other method as the Board of Directors
shall  determine  in good faith,  to reflect its fair  market  value.  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").  Portfolio securities primarily traded on
foreign  markets are generally  valued at the preceding  closing  values of such
securities on their respective exchanges. 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
maturities of 60 days or less are valued at amortized cost,  unless the Board of
Directors  determines such does not reflect the securities' fair value, in which
case these  securities  will be valued at their fair value as  determined by the
Board of Directors.  Debt instruments having a maturity greater than 60 days for
which market  quotations are readily  available are valued at the latest average
of the bid and asked  prices.  If there were no asked prices quoted on such day,
the  security is valued  using the closing bid price.  Options are valued at the
last sale price on the  exchange on which they are  listed.  If no sales of such
options have taken place that day, they will be valued at the mean between their
closing bid and asked prices.

OPTIONS.  The Fund may  purchase or write call or put options on  securities  or
indices. As a writer of call options,  the 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.  The Fund would incur a loss if the price of
the underlying  financial  instrument  increases  between the date the option is
written and the date on which the option is terminated. The Fund would realize a
gain,  to the extent of the premium,  if the price of the  financial  instrument
decreases between those dates.

As a purchaser of put options,  the 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, the Fund would


                                        6
                                     


THE GABELLI ABC FUND
NOTES TO FINANCIAL STATEMENTS (CONTINUED)
- --------------------------------------------------------------------------------
realize a gain upon sale or exercise.  If the price of the  underlying  security
increases,  the Fund would realize a loss upon sale or at expiration  date,  but
only to the extent of the premium paid. At December 31, 2003, there were no open
call options.

The option  activity  for  the Fund for the year ended  December 31, 2003 was as
follows:
                                                  NUMBER OF
CALL OPTIONS                                      CONTRACTS       PREMIUMS
- ------------                                      ---------       --------
Options outstanding at December 31, 2002 ..........     --        $     --
Options written during the period .................    750          80,248
Options exercised during the period ...............   (750)       $(80,248)
                                                     ------       ---------
Options outstanding at December 31, 2003 ..........      --              --
                                                     ======       =========

REPURCHASE  AGREEMENTS.  The 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, the Fund takes
possession  of an  underlying  debt  obligation  subject to an obligation of the
seller to repurchase,  and the Fund to resell,  the obligation at an agreed-upon
price and time, thereby  determining the yield during the Fund's holding period.
The Fund will always receive and maintain  securities as collateral whose market
value, including accrued interest,  will be at least equal to 102% 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. At December
31, 2003, there were no repurchase agreements.

FUTURES  CONTRACTS.  The 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,  the 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 the 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. The Fund recognizes a realized gain or loss when the
contract is closed. At December 31, 2003, there were no open futures contracts.

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 correlate with the
change in value of the hedged investments.  In addition,  there is the risk that
the 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 the 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.  The Fund records a realized  gain or loss when the short
position is closed out. By entering into a short sale, the Fund bears the market
risk of an unfavorable change in the price of the security sold short.


                                        7
                                     


THE GABELLI ABC FUND
NOTES TO FINANCIAL STATEMENTS (CONTINUED)
- --------------------------------------------------------------------------------
Dividends  on  short  sales  are  recorded  as an  expense  by the  Fund  on the
ex-dividend  date and  interest  expense is recorded on the  accrual  basis.  At
December 31, 2003, there were no open short sales.

FORWARD  FOREIGN  EXCHANGE  CONTRACTS.  The Fund 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 Fund records 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 Fund  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 Fund 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 Fund
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.

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

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


                                        8
                                     


THE GABELLI ABC FUND
NOTES TO FINANCIAL STATEMENTS (CONTINUED)
- --------------------------------------------------------------------------------
For the year ended  December 31, 2003,  reclassifications  were made to decrease
accumulated net investment income for $1,340,395 and to increase accumulated net
realized  gain on  investments  for $907,060,  with an offsetting  adjustment to
additional paid-in capital. These reclassifications, which have no impact on the
net asset value of the Fund, are primarily  attributable to certain  differences
in computation of distributable income and capital gains under Federal tax rules
versus accounting principles generally accepted in the United States,  including
the  Fund's  use of the tax  accounting  practice  known  as  equalization.  The
calculation  of net  investment  income  per share in the  financial  highlights
excludes these adjustments.

The tax  characteristics  of  distributions  paid  during the fiscal  year ended
December 31, 2003 and December 31, 2002 were as follows:



                                                        YEAR ENDED                 YEAR ENDED
                                                    DECEMBER 31, 2003          DECEMBER 31, 2002
                                                   ------------------          -----------------
                                                                              
      DISTRIBUTIONS PAID FROM:
      Ordinary income
         (inclusive of short term capital gains) ..    $  302,802                   $2,469,266
      Net long term capital gains .................     8,024,250                       78,612
                                                       ----------                   ----------
      Total distributions paid ....................    $8,327,052                   $2,547,878
                                                       ==========                   ==========


PROVISION  FOR  INCOME  TAXES.  The 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.

As of December 31, 2003, the components of  accumulated  earnings/(losses)  on a
tax basis were as follows:

      Undistributed ordinary income/(loss)
         (inclusive of short term capital gains) .........    $ (100,721)
      Net unrealized appreciation ........................     1,350,335
                                                              ----------
      Total accumulated gain .............................    $1,249,614
                                                              ==========

3.  INVESTMENT  ADVISORY  AGREEMENT.  The Fund has  entered  into an  investment
advisory  agreement (the "Advisory  Agreement")  with the Adviser which provides
that the Fund will pay the Adviser a fee,  computed  daily and paid monthly,  at
the annual rate of 1.00% of the value of the Fund's average daily net assets. In
accordance  with the  Advisory  Agreement,  the  Adviser  provides a  continuous
investment program for the Fund's portfolio,  oversees the administration of all
aspects of the Fund's  business  and  affairs and pays the  compensation  of all
Officers  and  Directors  of the Fund who are its  affiliates.  The  Adviser has
voluntarily  agreed to reduce its  advisory  fee by 0.50%,  but may  increase or
decrease  such  amounts  at any  time.  The  Fund's  expenses  were  reduced  by
$1,359,810 for the year ended December 31, 2003.

4.  DISTRIBUTION  PLAN. The Fund's Board of Directors has adopted a distribution
plan (the "Plan")  pursuant to Rule 12b-1 under the 1940 Act. For the year ended
December 31, 2003,  the Fund  incurred  distribution  costs payable to Gabelli &
Company,  Inc.,  an affiliate of the Adviser,  of $679,861,  or 0.25% of average
daily net  assets,  the annual  limitation  under the Plan.  Such  payments  are
accrued daily and paid monthly.  Effective January 1, 2003,  theDistributor  has
voluntarily  agreed to waive the full 0.25% fee indefinitely,  which has reduced
the Fund's expenses by $679,861 for the year ended December 31, 2003.


                                       9
                                     


THE GABELLI ABC FUND
NOTES TO FINANCIAL STATEMENTS (CONTINUED)
- --------------------------------------------------------------------------------
5.  PORTFOLIO  SECURITIES.  Purchases and sales of securities for the year ended
December 31, 2003, other than short term securities, aggregated $296,169,862 and
$150,025,493, respectively.

6.  TRANSACTIONS  WITH AFFILIATES.  During the year ended December 31, 2003, the
Fund paid brokerage commissions of $248,359 to Gabelli & Company, Inc.

The cost of  calculating  the Fund's net asset value per share is a Fund expense
pursuant to the  Advisory  Agreement  between the Fund and the  Adviser.  During
fiscal 2003, the Fund reimbursed the Adviser $34,800 in connection with the cost
of  computing  the Fund's net asset  value,  which is included in  miscellaneous
expenses on the Statement of Operations.

7. LINE OF  CREDIT.  The Fund has  access to an  unsecured  line of credit up to
$25,000,000  from the  custodian for temporary  borrowing  purposes.  Borrowings
under this  arrangement  bear  interest at 0.75% above the Federal Funds rate on
outstanding  balances.  There were no borrowings  during the year ended December
31, 2003.

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



                                                             YEAR ENDED                         YEAR ENDED
                                                           DECEMBER 31, 2003                 DECEMBER 31, 2002
                                                    -----------------------------      ----------------------------
                                                       SHARES          AMOUNT            SHARES          AMOUNT
                                                    ------------    -------------      -----------    -------------
                                                                                         
Shares sold ......................................   12,764,211     $ 125,709,683       20,404,013    $ 197,592,960
Shares issued upon reinvestment of dividends .....      654,597         6,434,682          195,131        1,881,060
Shares redeemed ..................................  (10,576,893)     (104,016,590)     (10,887,522)    (105,558,473)
                                                    ------------    -------------      -----------    -------------
  Net increase ...................................    2,841,915     $  28,127,775        9,711,622    $  93,915,547
                                                    ===========     =============      ===========    =============


9. CHANGE IN FUND'S AUDITOR.  On November 19, 2003, based on the  recommendation
of the Audit  Committee  of the Fund,  the Board of  Directors  voted to appoint
Ernst & Young LLP as the Fund's independent  auditor for the current fiscal year
ending December 31, 2003,  replacing  Grant Thornton LLP ("GT").  During the two
most recent  fiscal  years,  GT audit  reports  contained no adverse  opinion or
disclaimer  of  opinion;  nor were  the  reports  qualified  or  modified  as to
uncertainty,  audit scope,  or  accounting  principles.  Further,  there were no
disagreements  between  the  Fund  and  GTon  accounting  principles,  financial
statement  disclosure or audit scope,  which if not resolved to the satisfaction
of GT would have caused it to make reference to the  disagreements in connection
with its report.


                                       10
                                     


THE GABELLI ABC FUND
FINANCIAL HIGHLIGHTS
- --------------------------------------------------------------------------------
Selected data for a share of capital stock outstanding throughout each period:



                                                                           YEAR ENDED DECEMBER 31,
                                                           --------------------------------------------------------------
                                                             2003         2002         2001            2000        1999
                                                           --------     --------     --------        -------      -------
                                                                                                   
OPERATING PERFORMANCE:
   Net asset value, beginning of period ...............    $   9.64     $   9.65     $   9.45        $  9.44      $ 9.59
                                                           --------     --------     --------        -------      -------
   Net investment income ..............................        0.05         0.07         0.10           0.19         0.26
   Net realized and unrealized gain on investments ....        0.43         0.01         0.33           0.83         0.59
                                                           --------     --------     --------        -------      -------
   Total from investment operations ...................        0.48         0.08         0.43           1.02         0.85
                                                           --------     --------     --------        -------      -------
DISTRIBUTIONS TO SHAREHOLDERS:
   Net investment income ..............................       (0.01)       (0.05)       (0.09)         (0.12)       (0.14)
   Net realized gain on investments ...................       (0.28)       (0.04)       (0.14)         (0.89)       (0.86)
                                                           --------     --------     --------        -------      -------
   Total distributions ................................       (0.29)       (0.09)       (0.23)         (1.01)       (1.00)
                                                           --------     --------     --------        -------      -------
   NET ASSET VALUE, END OF PERIOD .....................    $   9.83     $   9.64     $   9.65        $  9.45      $  9.44
                                                           ========     ========     ========        =======      =======
   Total return+ ......................................        4.9%         0.9%          4.6%          10.9%         9.0%
                                                           ========     ========     ========        =======      =======
RATIOS TO AVERAGE NET ASSETS AND
  SUPPLEMENTAL DATA:
   Net assets, end of period (in 000's) ...............    $294,070     $261,014     $167,409        $62,372      $42,783
   Ratio of net investment income to average net assets        0.59%        0.74%        1.43%          1.55%        1.37%
   Ratio of operating expenses to average net assets
     before fees waived ...............................        1.40%        1.39%        1.46%(a)       1.50%(a)     1.47%
   Ratio of operating expenses
     to average net assets net of fees waived .........        0.65%        0.99%        1.46%(a)       1.50%(a)     1.47%
   Portfolio turnover rate ............................         244%         252%         308%           312%         672%


- --------------------------------
  +  Total return  represents  aggregate  total return of a hypothetical  $1,000
     investment at the beginning of the period and sold at the end of the period
     including reinvestment of dividends.
(a)  The fund incurred interest expense during the years ended December 31, 2001
     and  2000.  If  interest  expense  had not been  incurred,  the  ratios  of
     operating  expenses to average net assets  would have been 1.44% and 1.45%,
     respectively.

                 See accompanying notes to financial statements.


                                       11
                                     


THE GABELLI ABC FUND
REPORT OF ERNST & YOUNG LLP, INDEPENDENT AUDITORS
- --------------------------------------------------------------------------------
Shareholders and Board of Directors of
The Gabelli ABC Fund

We have audited the accompanying statement of assets and liabilities,  including
the portfolio of investments,  of The Gabelli ABC Fund (the "Fund"), a series of
Gabelli Investor Funds, Inc., as of December 31, 2003, and the related statement
of operations,  the statement of changes in net assets, and financial highlights
for the year then ended. These financial statements and financial highlights are
the responsibility of the Fund's management. Our responsibility is to express an
opinion on these  financial  statements  and financial  highlights  based on our
audits.  The  statement  of changes in net assets of the Fund for the year ended
December 31, 2002 and the financial highlights for each of the four years in the
period then ended were audited by other  auditors whose report dated January 31,
2003,  expressed  an  unqualified  opinion  on those  statements  and  financial
highlights.

We conducted our audit in accordance with auditing standards  generally accepted
in the United States. Those standards require that we plan and perform the audit
to obtain  reasonable  assurance  about  whether the  financial  statements  and
financial  highlights  are free of  material  misstatement.  An  audit  includes
examining,  on a test basis,  evidence supporting the amounts and disclosures in
the financial  statements  and financial  highlights.  Our  procedures  included
confirmation of securities owned as of December 31, 2003, by correspondence with
the  Fund's  custodian  and  brokers.  An  audit  also  includes  assessing  the
accounting principles used and significant estimates made by management, as well
as evaluating the overall financial statement presentation.  We believe that our
audit provides a reasonable basis for our opinion.

In our opinion,  the financial  statements and financial  highlights referred to
above present fairly, in all material  respects,  the financial  position of The
Gabelli ABC Fund at  December  31,  2003,  the  results of its  operations,  the
changes in its net assets, and the financial highlights for the year then ended,
in  conformity  with  accounting  principles  generally  accepted  in the United
States.

                                                            /s/ERNST & YOUNG LLP
New York, New York
February 10, 2004

- --------------------------------------------------------------------------------
                   2003 TAX NOTICE TO SHAREHOLDERS (Unaudited)

  For the fiscal year ended December 31, 2003, the Fund paid to shareholders, on
  December 27, 2003, an ordinary  income  dividend  (comprised of net investment
  income and short term  capital  gains)  totaling  $0.286.  For the fiscal year
  ended December 31, 2003,  4.90% of the ordinary income dividend  qualifies for
  the dividend received  deduction  available to corporations,  and 7.39% of the
  ordinary income distribution was qualifying dividend income.

  U.S. GOVERNMENT INCOME:
  The percentage of the ordinary  income dividend paid by the Fund during fiscal
  year 2003 which was derived from U.S.  Treasury  securities  was 12.71%.  Such
  income is exempt from state and local tax in all states. However, many states,
  including New York and California,  allow a tax exemption for a portion of the
  income earned only if a mutual fund has invested at least 50% of its assets at
  the  end of  each  quarter  of the  Fund's  fiscal  year  in  U.S.  Government
  securities.  The Gabelli ABC Fund met this strict  requirement in 2003. Due to
  the diversity in state and local tax law, it is  recommended  that you consult
  your personal tax advisor as to the applicability of the information  provided
  to your specific situation.
- --------------------------------------------------------------------------------

                                       12
                                     


THE GABELLI ABC FUND
ADDITIONAL FUND INFORMATION (UNAUDITED)
- --------------------------------------------------------------------------------
The  business  and affairs of the Fund are managed  under the  direction  of the
Fund's Board of Directors.  Information pertaining to the Directors and officers
of the Fund is set forth below. The Fund's  Statement of Additional  Information
includes  additional  information  about The Gabelli ABC Fund  Directors  and is
available,  without charge, upon request, by calling 800-GABELLI  (800-422-3554)
or by  writing  to The  Gabelli  ABC  Fund  at One  Corporate  Center,  Rye,  NY
10580-1422.



                             TERM OF          NUMBER OF
NAME, POSITION(S)          OFFICE AND      FUNDS IN FUND
    ADDRESS 1               LENGTH OF     COMPLEX OVERSEEN   PRINCIPAL OCCUPATION(S)                 OTHER DIRECTORSHIPS
     AND AGE              TIME SERVED 2      BY DIRECTOR     DURING PAST FIVE YEARS                  HELD BY DIRECTOR
- ----------------          -------------   -----------------  ----------------------                  ------------------
INTERESTED DIRECTORS 3:
                                                                                         
MARIO J. GABELLI           Since 1993          24            Chairman of the Board and               Director of Morgan Group
Director and                                                 Chief Executive Officer of              Holdings, Inc. (holding
Chief Investment Officer                                     Gabelli Asset Management Inc.           company); Vice Chairman of
Age: 61                                                      and Chief Investment Officer            Lynch Corporation (diversified
                                                             of Gabelli Funds, LLC                   manufacturing)
                                                             and GAMCO Investors, Inc.;
                                                             Vice Chairman and Chief Executive
                                                             Officer of Lynch Interactive
                                                             Corporation (multimedia and
                                                             services)

KARL OTTO POHL             Since 1993          33            Member of the Shareholder Committee     Director of Gabelli Asset
Director                                                     of Sal Oppenheim Jr. & Cie              Management Inc. (investment
Age: 74                                                      (private investment bank);              management), Chairman,
                                                             Former President of the  Deutsche       Incentive Capital and Incentive
                                                             Bundesbank and Chairman of its          Asset Management (Zurich);
                                                             Central Bank Council (1980-1991)        Director at Sal Oppenheim Jr.
                                                                                                     & Cie, Zurich
NON-INTERESTED DIRECTORS:
- ------------------------
ANTHONY J. COLAVITA        Since 1993          35            President and Attorney at Law in                     --
Director                                                     the law firm of Anthony J.
Age: 68                                                      Colavita, P.C.

VINCENT D. ENRIGHT         Since 1993          12            Former Senior Vice President and                     --
Director                                                     Chief Financial Officer of KeySpan
Age: 60                                                      Energy Corporation

MARY E. HAUCK              Since 2000           6            Retired Senior Manager of the Gabelli                --
Director                                                     O'Connor Fixed Income Mutual Funds
Age: 61                                                      Management Company

WERNER J. ROEDER, MD       Since 1993          26            Vice President/Medical Affairs, Lawrence             --
Director                                                     Hospital Center and practicing private physician
Age: 63

OFFICERS:
BRUCE N. ALPERT            Since 2003          --            Executive Vice President and Chief Operating         --
President                                                    Officer of Gabelli Funds, LLC since 1988 and
Age: 52                                                      an officer of all mutual funds advised by
                                                             Gabelli Funds, LLC and its affiliates.
                                                             Director and President of Gabelli Advisers, Inc.

JAMES E. MCKEE             Since 1995          --            Vice President, General Counsel and Secretary        --
Vice President and                                           of Gabelli Asset Management Inc. since 1999
Secretary                                                    and GAMCO Investors, Inc. since 1993;
Age: 40                                                      Secretary of all mutual funds advised by
                                                             Gabelli Advisers, Inc. and Gabelli Funds, LLC


- --------------------------------------------------------------------------------
  1 Address: One Corporate Center, Rye, NY 10580-1422, unless otherwise noted.
  2 Each Director will hold office for an indefinite  term until the earliest of
    (i) the next  meeting of  shareholders  if any,  called  for the  purpose of
    considering  the  election or  re-election  of such  Director  and until the
    election and qualification of his or her successor,  if any, elected at such
    meeting,  or (ii) the date a Director  resigns or retires,  or a Director is
    removed by the Board of Directors or  shareholders,  in accordance  with the
    Fund's By-Laws and Articles of Incorporation.
  3 "Interested  person" of the Fund as defined in the Investment Company Act of
    1940.  Messrs.  Gabelli and Pohl are each considered an "interested  person"
    because  of their  affiliation  with  Gabelli  Funds,  LLC which acts as the
    Fund's investment adviser.


                                       13
                                     

- --------------------------------------------------------------------------------
     GABELLI FUNDS AND YOUR PERSONAL PRIVACY
- --------------------------------------------------------------------------------
     WHO ARE WE?
     The Gabelli Funds are investment  companies  registered with the Securities
     and Exchange  Commission  under the Investment  Company Act of 1940. We are
     managed by Gabelli  Funds LLC,  Gabelli  Advisers,  Inc. and Gabelli  Fixed
     Income,  LLC,  which are  affiliated  with Gabelli  Asset  Management  Inc.
     Gabelli Asset  Management is a publicly-held  company that has subsidiaries
     that provide  investment  advisory or  brokerage  services for a variety of
     clients.

     WHAT KIND OF NON-PUBLIC INFORMATION DO WE COLLECT ABOUT YOU IF YOU BECOME A
     GABELLI CUSTOMER?
     If you apply to open an  account  directly  with us,  you will be giving us
     some non-public  information about yourself.  The non-public information we
     collect about you is:
     o  INFORMATION  YOU GIVE US ON YOUR  APPLICATION  FORM.  This could include
        your name,  address,  telephone  number,  social security  number,  bank
        account number, and other information.
     o  INFORMATION  ABOUT YOUR  TRANSACTIONS WITH US, ANY TRANSACTIONS WITH OUR
        AFFILIATES  AND  TRANSACTIONS  WITH  THE  ENTITIES  WE HIRE  TO  PROVIDE
        SERVICES TO YOU.  This would include  information  about the shares that
        you buy or redeem, and the deposits and withdrawals that you make. If we
        hire someone else to provide  services--like  a transfer  agent--we will
        also have information  about the  transactions  that you conduct through
        them.

     WHAT INFORMATION DO WE DISCLOSE AND TO WHOM DO WE DISCLOSE IT?
     We do not disclose any non-public personal  information about our customers
     or former  customers  to anyone,  other than our  affiliates,  our  service
     providers who need to know such  information and as otherwise  permitted by
     law. If you want to find out what the law permits, you can read the privacy
     rules adopted by the Securities and Exchange Commission. They are in volume
     17 of the Code of Federal Regulations, Part 248. The Commission often posts
     information about its regulations on its web site, www.sec.gov.

     WHAT DO WE DO TO PROTECT YOUR PERSONAL INFORMATION?
     We restrict  access to  non-public  personal  information  about you to the
     people who need to know that  information  in order to provide  services to
     you or the Fund and to ensure that we are complying with the laws governing
     the securities business. We maintain physical,  electronic,  and procedural
     safeguards to keep your personal information confidential.
- --------------------------------------------------------------------------------





                             GABELLI FAMILY OF FUNDS

VALUE ________________________________________
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. (MULTICLASS)
                                        PORTFOLIO MANAGER: MARIO J. GABELLI, CFA

GABELLI BLUE CHIP VALUE FUND
Seeks long term growth of capital  through  investment  primarily  in the common
stocks of established  companies which are temporarily out of favor.  The fund's
objective  is to  identify a catalyst or sequence of events that will return the
company to a higher value.
(MULTICLASS)                              PORTFOLIO MANAGER: BARBARA MARCIN, CFA

GABELLI WESTWOOD EQUITY FUND
Seeks to invest  primarily in the common stock of  well-seasoned  companies that
have  recently  reported  positive  earnings  surprises  and are  trading  below
Westwood's  proprietary  growth rate estimates.  The Fund's primary objective is
capital appreciation.
(MULTICLASS)                                   PORTFOLIO MANAGER: SUSAN M. BYRNE

FOCUSED VALUE ______________________________
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

SMALL CAP VALUE ____________________________
GABELLI SMALL CAP FUND
Seeks  to  invest  primarily  in  common  stock  of  smaller  companies  (market
capitalizations  less  than $1  billion)  believed  to have  rapid  revenue  and
earnings growth potential. The Fund's primary objective is capital appreciation.
(MULTICLASS)                            PORTFOLIO MANAGER: MARIO J. GABELLI, CFA

GABELLI WOODLAND SMALL CAP VALUE FUND
Seeks to invest  primarily  in the common  stocks of smaller  companies  (market
capitalizations  less  than  $1.5  billion)  believed  to  be  undervalued  with
shareholder  oriented management teams that are employing strategies to grow the
company's  value.  The  Fund's  primary   objective  is  capital   appreciation.
(MULTICLASS)                          PORTFOLIO MANAGER: ELIZABETH M. LILLY, CFA

GROWTH ______________________________________
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. (MULTICLASS)        PORTFOLIO MANAGER: HOWARD F. WARD, CFA

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

AGGRESSIVE GROWTH _________________________
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

MICRO-CAP ___________________________________
GABELLI WESTWOOD MIGHTY MITES(SM) 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

EQUITY INCOME _______________________________
GABELLI EQUITY INCOME FUND
Seeks to invest primarily in equity securities with above market average yields.
The Fund pays monthly  dividends  and seeks a high level of total return with an
emphasis on income. (MULTICLASS)        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)                            CO-PORTFOLIO MANAGERS: SUSAN M. BYRNE
                                                               MARK FREEMAN, CFA

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. (MULTICLASS)                     PORTFOLIO MANAGER: SUSAN M. BYRNE

SPECIALTY EQUITY ____________________________
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 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

SECTOR ______________________________________
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 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. (MULTICLASS)
                                                 PORTFOLIO MANAGER: CAESAR BRYAN

GABELLI UTILITIES FUND
Seeks to provide a high level of total return  through a combination  of capital
appreciation and current income. (MULTICLASS)                       TEAM MANAGED

MERGER AND ARBITRAGE _____________________
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

CONTRARIAN_________________________________
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

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

QUANTITATIVE_________________________________
NED DAVIS RESEARCH ASSET  ALLOCATION  FUND
Seeks  to  achieve  returns  greater  then  the  weighted  composite   benchmark
consisting  of 60% in the S&P 500  Index  and 40% in the  Lehman  Long Term U.S.
Government Bond Index through a flexible asset allocation  strategy.  The Fund's
primary objective is capital appreciation.
(MULTICLASS)                                                        TEAM MANAGED

SMALL CAP GROWTH __________________________
GABELLI WESTWOOD SMALLCAP EQUITY FUND
Seeks to invest primarily in smaller  capitalization  equity securities - market
caps of $1.5 billion or less. The Fund's primary  objective is long-term capital
appreciation. (MULTICLASS)
                            CO-PORTFOLIO MANAGERS: CHRISTOPHER J. MACDONALD, CFA

FIXED INCOME ________________________________
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: MARK FREEMAN, CFA

CASH MANAGEMENT-MONEY MARKET __________
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

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  securities  and repurchase  agreements.  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

THE GLOBAL FUNDS INVEST IN FOREIGN SECURITIES WHICH INVOLVE RISKS NOT ORDINARILY
ASSOCIATED WITH INVESTMENTS IN DOMESTIC ISSUES,  INCLUDING CURRENCY FLUCTUATION,
ECONOMIC AND POLITICAL RISKS.

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.

  TO RECEIVE A PROSPECTUS, CALL 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.



                              THE GABELLI ABC FUND
                              One Corporate Center
                            Rye, New York 10580-1422
                                   800-GABELLI
                                  800-422-3554
                                FAX: 914-921-5118
                            WEBSITE: WWW.GABELLI.COM
                            E-MAIL: INFO@GABELLI.COM
                   Net Asset Value available daily by calling
                           800-GABELLI after 6:00 P.M.

                BOARD OF DIRECTORS
Mario J. Gabelli, CFA           Mary E. Hauck
CHAIRMAN AND CHIEF              (RETIRED) SENIOR PORTFOLIO MANAGER
INVESTMENT OFFICER              GABELLI-O'CONNOR FIXED INCOME
GABELLI ASSET MANAGEMENT INC.   MUTUAL FUND MANAGEMENT CO.

Anthony J. Colavita             Karl Otto Pohl
ATTORNEY-AT-LAW                 FORMER PRESIDENT
ANTHONY J. COLAVITA, P.C.       DEUTSCHE BUNDESBANK

Vincent D. Enright              Werner J. Roeder, MD
FORMER SENIOR VICE PRESIDENT    VICE PRESIDENT/MEDICAL AFFAIRS
AND CHIEF FINANCIAL OFFICER     LAWRENCE HOSPITAL CENTER
KEYSPAN ENERGY CORP.

                    OFFICERS
Bruce N. Alpert                 James E. McKee
PRESIDENT                       SECRETARY

                   DISTRIBUTOR
              Gabelli & Company, Inc.

   CUSTODIAN, TRANSFER AGENT AND DIVIDEND AGENT
        State Street Bank and Trust Company

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

[GRAPHIC OMITTED]
GABELLI PHOTO

THE
GABELLI
ABC
FUND

- --------------------------------------------------------------------------------
This report is submitted for the general  information of the shareholders of The
Gabelli ABC Fund. It is not authorized for distribution to prospective investors
unless preceded or accompanied by an effective prospectus.
- --------------------------------------------------------------------------------
GAB408Q403SR


                                                                   ANNUAL REPORT
                                                               DECEMBER 31, 2003



ITEM 2. CODE OF ETHICS.

     (a) The registrant, as of the end of the period covered by this report, has
         adopted a code of ethics  that  applies to the  registrant's  principal
         executive officer,  principal financial officer,  principal  accounting
         officer  or  controller,   or  persons  performing  similar  functions,
         regardless of whether these  individuals are employed by the registrant
         or a third party.

     (b) No response required.

     (c) There have been no amendments, during the period covered by this
         report, to a provision of the code of ethics that applies to the
         registrant's principal executive officer, principal financial officer,
         principal accounting officer or controller, or persons performing
         similar functions, regardless of whether these individuals are employed
         by the registrant or a third party, and that relates to any element of
         the code of ethics description.

     (d) The registrant has not granted any waivers, including an implicit
         waiver, from a provision of the code of ethics that applies to the
         registrant's principal executive officer, principal financial officer,
         principal accounting officer or controller, or persons performing
         similar functions, regardless of whether these individuals are employed
         by the registrant or a third party, that relates to one or more of the
         items set forth in paragraph (b) of this item's instructions.

ITEM 3. AUDIT COMMITTEE FINANCIAL EXPERT.

As of the end of the period covered by the report, the registrant's board of
directors has determined that Vincent D. Enright is qualified to serve as an
audit committee financial expert serving on its audit committee and that he is
"independent," as defined by this Item 3.

ITEM 4. PRINCIPAL ACCOUNTANT FEES AND SERVICES.

     (a) AUDIT FEES: The aggregate fees billed for each of the last two fiscal
         years for professional services rendered by the principal accountant
         for the audit of the registrant's annual financial statements or
         services that are normally provided by the accountant in connection
         with statutory and regulatory filings or engagements for those fiscal
         years are $25,000 in 2003 and $31,238 in 2002.





     (b) AUDIT-RELATED  FEES:  The aggregate fees billed in each of the last two
         fiscal  years for  assurance  and  related  services  by the  principal
         accountant that are reasonably  related to the performance of the audit
         of the  registrant's  financial  statements  and are not reported under
         paragraph (a) of this Item are $0 in 2003 and $0 in 2002.

     (c) TAX FEES: The aggregate fees billed in each of the last two fiscal
         years for professional services rendered by the principal accountant
         for tax compliance, tax advice, and tax planning are $3,400 in 2003 and
         $0 in 2002.

         Tax fees represent tax compliance services provided in connection with
         the review of the Registrant's tax returns.

     (d) ALL  OTHER  FEES:  The  aggregate  fees  billed in each of the last two
         fiscal  years for  products  and  services  provided  by the  principal
         accountant,  other than the services reported in paragraphs (a) through
         (c) of this Item are $0 in 2003 and $0 in 2002.

     (e)(1)   Disclose the audit committee's pre-approval policies and
              procedures described in paragraph (c)(7) of Rule 2-01 of
              Regulation S-X.

              Pre-Approval Policies and Procedures. The Audit Committee
              ("Committee") of the registrant is responsible for pre-approving
              (i) all audit and permissible non-audit services to be provided by
              the independent auditors to the registrant and (ii) all
              permissible non-audit services to be provided by the independent
              auditors to Gabelli and any affiliate of Gabelli that provides
              services to the registrant (a "Covered Services Provider") if the
              independent auditors' engagement relates directly to the
              operations and financial reporting of the registrant. The
              Committee may delegate its responsibility to pre-approve any such
              audit and permissible non-audit services to the Chairperson of the
              Committee, and the Chairperson must report to the Committee, at
              its next regularly scheduled meeting after the Chairperson's
              pre-approval of such services, his or her decision(s). The
              Committee may also establish detailed pre-approval policies and
              procedures for pre-approval of such services in accordance with
              applicable laws, including the delegation of some or all of the
              Committee's pre-approval responsibilities to other persons (other
              than Gabelli or the registrant's officers). Pre-approval by the
              Committee of any permissible non-audit services is not required so
              long as: (i) the aggregate amount of all such permissible
              non-audit services provided to the registrant, Gabelli and any
              Covered Services Provider constitutes not more than 5% of the
              total amount of revenues paid by the registrant to its independent
              auditors during the fiscal year in which the permissible non-audit
              services are provided; (ii) the permissible non-audit services
              were not recognized by the registrant at the time of the
              engagement to be non-audit services; and (iii) such services are
              promptly brought to the attention of the Committee and approved by
              the Committee or the Chairperson prior to the completion of the
              audit.





     (e)(2)   The percentage of services described in each of paragraphs (b)
              through (d) of this Item that were approved by the audit committee
              pursuant to paragraph (c)(7)(i)(C) of Rule 2-01 of Regulation S-X
              are as follows:

                           (b) N/A

                           (c) 100%

                           (d) N/A

     (f) The percentage of hours expended on the principal accountant's
         engagement to audit the registrant's financial statements for the most
         recent fiscal year that were attributed to work performed by persons
         other than the principal accountant's full-time, permanent employees
         was zero percent (0%).

     (g) The aggregate non-audit fees billed by the registrant's accountant for
         services rendered to the registrant, and rendered to the registrant's
         investment adviser (not including any sub-adviser whose role is
         primarily portfolio management and is subcontracted with or overseen by
         another investment adviser), and any entity controlling, controlled by,
         or under common control with the adviser that provides ongoing services
         to the registrant for each of the last two fiscal years of the
         registrant was $62,400 in 2003 and $0 in 2002.

     (h) The registrant's audit committee of the board of directors HAS
         considered whether the provision of non-audit services that were
         rendered to the registrant's investment adviser (not including any
         sub-adviser whose role is primarily portfolio management and is
         subcontracted with or overseen by another investment adviser), and any
         entity controlling, controlled by, or under common control with the
         investment adviser that provides ongoing services to the registrant
         that were not pre-approved pursuant to paragraph (c)(7)(ii) of Rule
         2-01 of Regulation S-X is compatible with maintaining the principal
         accountant's independence.

ITEM 5. AUDIT COMMITTEE OF LISTED REGISTRANTS.

Not applicable.

ITEM 6. [RESERVED]

ITEM 7. DISCLOSURE OF PROXY VOTING POLICIES AND PROCEDURES FOR CLOSED-END
MANAGEMENT INVESTMENT COMPANIES.

Not applicable.





ITEM 8. PURCHASES OF EQUITY SECURITIES BY CLOSED-END MANAGEMENT INVESTMENT
COMPANY AND AFFILIATED PURCHASERS.

Not applicable.

ITEM 9. SUBMISSION OF MATTERS TO A VOTE OF SECURITY HOLDERS.

Not yet applicable.

ITEM 10. CONTROLS AND PROCEDURES.

     (a)  The registrant's principal executive and principal financial officers,
          or persons performing similar functions, have concluded that the
          registrant's disclosure controls and procedures (as defined in Rule
          30a-3(c) under the Investment Company Act of 1940, as amended (the
          "1940 Act") (17 CFR 270.30a-3(c))) are effective, as of a date within
          90 days of the filing date of the report that includes the disclosure
          required by this paragraph, based on their evaluation of these
          controls and procedures required by Rule 30a-3(b) under the 1940 Act
          (17 CFR 270.30a-3(b)) and Rules 13a-15(b) or 15d-15(b) under the
          Securities Exchange Act of 1934, as amended (17 CFR 240.13a-15(b) or
          240.15d-15(b)).

     (b)  There were no changes in the registrant's internal control over
          financial reporting (as defined in Rule 30a-3(d) under the 1940 Act
          (17 CFR 270.30a-3(d)) that occurred during the registrant's last
          fiscal half-year (the registrant's second fiscal half-year in the case
          of an annual report) that has materially affected, or is reasonably
          likely to materially affect, the registrant's internal control over
          financial reporting.

ITEM 11. EXHIBITS.

     (a)(1)   Code of ethics,  or any amendment  thereto,  that is the subject
              of disclosure  required by Item 2 is attached hereto.

     (a)(2)   Certifications pursuant to Rule 30a-2(a) of the Investment Company
              Act of 1940, as amended, are attached hereto.

     (a)(3)   Not applicable.

     (b)      Certifications pursuant to Rule 30a-2(b) of the Investment Company
              Act of 1940, as amended, are attached hereto.





                                   SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934 and the
Investment Company Act of 1940, the registrant has duly caused this report to be
signed on its behalf by the undersigned, thereunto duly authorized.

(registrant)                                Gabelli Investor Funds, Inc.
            --------------------------------------------------------------------

By (Signature and Title)*                   /s/ Bruce N. Alpert
                          ------------------------------------------------------
                                            Bruce N. Alpert, Principal Executive
                                            Officer


Date                                        March 9, 2004
    ----------------------------------------------------------------------------


Pursuant to the requirements of the Securities Exchange Act of 1934 and the
Investment Company Act of 1940, this report has been signed below by the
following persons on behalf of the registrant and in the capacities and on the
dates indicated.


By (Signature and Title)*                   /s/ Bruce N. Alpert
                         -------------------------------------------------------
                                            Bruce N. Alpert, Principal Executive
                                            Officer and Principal Financial
                                            Officer


Date                                        March 9, 2004
    ----------------------------------------------------------------------------



* Print the name and title of each signing officer under his or her signature