SECURITIES AND EXCHANGE COMMISSION
                         WASHINGTON, DC 20549

                             FORM 10-QSB

(Mark One)

[X]  ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES
     EXCHANGE ACT OF 1934

     For the quarter ended October 31, 1999

                                  OR

[  ]      TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE
          SECURITIES EXCHANGE ACT OF 1934

     For the transition period from __________ to __________


Commission file number 0-011013

                      COMSTOCK INDUSTRIES, INC.
             --------------------------------------------
        (Exact name of registrant as specified in its charter)

Nevada                                                      75-2040527
- ----------                                             ---------------
(State or other jurisdiction         (IRS Employer Identification No.)
of incorporation or organization)

1470 Egret Road, Homestead, FL                                   33035
- --------------------------------------------                  --------
(Address of principal executive office)                     (Zip Code)

Registrant's telephone number, including area code:  305-470-9100

Check whether the issuer: (1) has filed all reports required to be
filed by Section 13 or 15(d) of the Exchange Act during the past 12
months (or for such shorter period that the registrant was required
to file such reports), and (2) has been subject to the filing
requirements for at least the past 90 days:

                           YES [X] NO [  ]

State the number of shares outstanding of each of the issuer's
classes of common equity, as of the latest practicable date:  As of
October 31, 1999, there were 8,185,885 shares of the Registrant's
$.10 par value common stock outstanding.

Transitional Small Business Disclosure Format (check one):

                           YES [  ]  NO [X]

                    PART I.  FINANCIAL INFORMATION

ITEM 1.   FINANCIAL STATEMENTS

     Balance Sheet

     Statements of Operations

     Statements of Cash Flows

     Notes to Financial Statements
                      COMSTOCK INDUSTRIES, INC.
                    (A Development Stage Company)
                            Balance Sheet


                                            
ASSETS

                                  October         October
                                  31, 1999        31, 1998
                                  -------------   --------------


CURRENT ASSETS

  Cash                                         $ 0            $ 0
                                              ----           ----
    Total Current Assets                         0              0
                                              ----           ----
    TOTAL ASSETS                               $ 0            $ 0
                                               ===            ===

LIABILITIES AND STOCKHOLDERS' EQUITY
(DEFICIT)

CURRENT LIABILITIES

  Accounts Payable                             $ 0            $ 0
                                              ----           ----
    Total Current Liabilities                    0              0
                                              ----           ----
    Total Liabilities                            0              0
                                              ----           ----

STOCKHOLDERS' EQUITY (DEFICIT)

  Common stock: 15,000,000                 818,589        818,589
    shares authorized
    of $0.10 par value,
    8,185,885 shares issued
    and outstanding

  Additional paid-in capital             (698,879)      (698,879)


  Deficit accumulated during the         (119,710)      (119,710)
  development stage                      -----------    -----------

    Total Stockholders' Equity           0              0
    (Deficit)                            ----           ----

    TOTAL LIABILITIES AND                $ 0            $ 0
    STOCKHOLDERS' EQUITY                 ===            ===


The accompanying notes are an integral part of these financial
statements



                      COMSTOCK INDUSTRIES, INC.
                    (A Development Stage Company)
                       Statements of Operations



                                                                     
                                                   For the 6-month Period
                                                   Ended

                                                       October 31, 1999       October 31, 1998
                                                      -----------------      -----------------

REVENUES                                                                $ 0                   $ 0
                                                                       ----                  ----

EXPENSES

 General and administrative expenses                                      0                     0
                                                                       ----                  ----
TOTAL OPERATING EXPENSES                                                  0                     0
                                                                       ----                  ----
LOSS FROM DISCONTINUED OPERATIONS (Note 3)                                0                     0
                                                                       ----                  ----
NET LOSS                                                                $ 0                   $ 0
                                                                        ===                   ===
BASIC NET LOSS PER SHARE                                                $ 0                   $ 0
  OF COMMON STOCK                                                       ===                   ===

BASIC WEIGHTED AVERAGE
  NUMBER OF SHARES                                                8,185,885             8,815,885
  OUTSTANDING                                                      ========              ========



The accompanying notes are an integral part of these financial
statements



                          COMSTOCK INDUSTRIES, INC.
                        (A Development Stage Company)
                           Statements of Cash Flows


     
                                                                          
                                                        For the 6-month Period
                                                        Ended

                                                            October 31, 1999       October 31, 1998
                                                           -----------------      -----------------

     CASH FLOWS FROM OPERATING ACTIVITIES

       Net Loss                                                              $ 0                   $ 0
                                                                            ----                  ----
       Adjustments to reconcile net loss to net cash                           0                     0
        used by operating activities                                        ----                  ----

         Increase in accounts payable                                          0                     0
                                                                            ----                  ----
           Net Cash Used by Operating Activities                               0                     0
                                                                            ----                  ----

     CASH FLOWS FROM INVESTING ACTIVITIES

     CASH FLOWS FROM FINANCING ACTIVITIES

       Issuance of common stock for cash                                       0                     0
                                                                            ----                  ----
       Contributed capital                                                     0                     0
                                                                            ----                  ----
         Net Cash Provided by Financing Activities                             0                     0
                                                                            ----                  ----
     NET INCREASE (DECREASE) IN CASH                                           0                     0
                                                                            ----                  ----
     CASH AT BEGINNING OF PERIOD                                               0                     0
                                                                            ----                  ----
     CASH AT END OF PERIOD                                                   $ 0                   $ 0
                                                                             ===                   ===

     CASH PAID FOR:

      Interest                                                               $ 0                   $ 0
                                                                            ----                  ----
      Income Taxes                                                           $ 0                   $ 0
                                                                            ----                  ----
     


     The accompanying notes are an integral part of these financial statements



                    COMSTOCK INDUSTRIES, INC.
                  (A Development Stage Company)
                Notes to the Financial Statements


     NOTE 1 -       ORGANIZATION AND HISTORY

            Comstock Industries, Inc. was organized under the
            laws of the State of Nevada on  April 3, 1928 as
            Canadian Metals Syndicate, Inc.  The name of the
            Company was changed on August 17, 1983 to Comstock
            Industries, Inc.  Comstock Industries, Inc. is
            considered a development stage company as defined
            in SFAS No. 7.

            a.  Accounting Method

            Comstock Industries, Inc.'s financial statements
            are prepared using the accrual method of
            accounting.  Comstock Industries, Inc. has elected
            an April 30 year end.

            b.  Cash and Cash Equivalents

            Cash equivalents include short-term, highly liquid
            investments with maturities of three months or less
            at the time of acquisition.

            c.  Basic Loss Per Share

            The computations of basic loss per share of common
            stock are based on the weighted average number of
            shares outstanding during the period of the
            financial statements.

            d.  Estimates

            The preparation of financial statements in
            conformity with generally accepted accounting
            principles requires management to make estimates
            and assumptions that affect the reported amounts of
            assets and liabilities and disclosure of contingent
            assets and liabilities at the date of the financial
            statements and the reported amounts of revenues and
            expenses during the reporting period.  Actual
            results could differ from those estimates.



                    COMSTOCK INDUSTRIES, INC.
                  (A Development Stage Company)
                Notes to the Financial Statements


     NOTE 2 -       GOING CONCERN

            Comstock Industries, Inc.'s financial statements
            are prepared using generally accepted accounting
            principles applicable to a going concern which
            contemplates the realization of assets and
            liquidation of liabilities in the normal course of
            business.  However, Comstock Industries, Inc. does
            not have significant cash or other material assets,
            nor does it have an established source of revenues
            sufficient to cover its operating costs and to
            allow it to continue as a going concern.  It is the
            intent of Comstock Industries, Inc. to seek a
            merger with an existing, operating company.  Until
            that time, shareholders of Comstock Industries,
            Inc. have committed to meeting its minimal
            operating needs.

     NOTE 3 -       DISCONTINUED OPERATIONS

            Comstock Industries, Inc. has been inactive since
            1983.  Therefore, all revenues generated by
            Comstock Industries, Inc. have been netted against
            the expenses and are grouped into the discontinued
            operations line on the statement of operations.



     ITEM 2.        MANAGEMENT'S DISCUSSION AND ANALYSIS OR
                    PLAN OF OPERATION

     Special Note Regarding Forward-Looking Statements

     Certain statements in this report and elsewhere (such as
     in other filings by us with the Securities and Exchange
     Commission ("SEC"), press releases, presentations by us or
     our management and oral statements) may constitute
     "forward-looking statements" within the meaning of the
     Private Securities Litigation Reform Act of 1995.  Words
     such as "expects", "anticipates", "intends", "plans",
     "believes", "seeks", "estimates" and "should", and
     variations of these words and similar expressions, are
     intended to identify these forward-looking statements.
     Our actual results could differ materially from those
     anticipated in these forward-looking statements.  Factors
     that might cause or contribute to such differences
     include, among others factors, competitive pressures, the
     growth rate of industry and commerce, constantly changing
     technology, and market acceptance of Comstock Industries,
     Inc.'s products and services.  We undertake no obligation
     to publicly release the result of any revisions to these
     forward-looking statements that we may make to reflect
     events or circumstances after the date hereof or the
     occurrence of unanticipated events.

     Plan of Operation

            Comstock Industries has not had any revenues from
     operations during the 3-month period ended October 31,
     1999.  All of its activities during the 3-month period
     ended July 31, 1999 were devoted to establishing a
     business plan and conducting limited financing activities
     to obtain working capital.

            During the 3-month period ended October 31, 1999,
     Comstock Industries generated no revenue and incurred no
     expenses.

            Comstock Industries will be required to raise
     additional funds during the next 12 months to meet its
     cash requirements.

            Comstock Industries has not undertaken any product
     research and development during the 3-month period ended
     October 31, 1999.

            Comstock Industries does not expect to purchase or
     sell any plant or significant equipment.

            Comstock Industries does not expect any significant
     changes in its number of employees.

     Year 2000

     Overview.

            Comstock Industries, Inc. has evaluated the
     potential impact of the situation commonly referred to as
     the "Year 2000 problem" or "Y2K problem".  The Y2K problem
     concerns the inability of information systems, primarily
     computer software programs, to properly recognize and
     process date sensitive information relating to the year
     2000 and beyond.  Many of the world's computer systems
     currently record years in a two-digit format.  These
     computer systems will be unable to properly interpret
     dates beyond the year 1999, which could lead to business
     disruptions in the United States and internationally.  The
     potential costs and uncertainties associated with the Y2K
     problem will depend on a number of factors, including
     software, hardware and the nature of the industry in which
     a company operates.

     Equipment and Systems.

            At this time, we do not own any assets with
     embedded computer chips or programs, and we do not own or
     operate any information systems which are the subject of
     Y2K problem.  Management believes that any assets with
     embedded computer chips or programs or information systems
     that we may acquire in the future will not be subject to
     the Y2K problem because they will be Y2K compliant.
     Therefore, we do not expect to experience any Y2K failures.

     Other Entity Compliance.

            Comstock Industries, Inc. does not engage in
     electronic data interchange with any other entity.
     Therefore, management believes it does not have any Y2K
     exposure directly from other entities and their failure to
     be Y2K compliant.  However, in the event such other
     entities experience Y2K failures, we may be affected by
     such Y2K failures in ways that we are unable to predict
     and that are not yet apparent to us.

     Contingency Planning.

            Management does not have a contingency plan in the
     event a critical service, supplier or customer experiences
     a Y2K failure.  Management does not expect any such
     failure to have a material impact on Comstock Industries,
     Inc. because it is in the development stage and uses few
     services and suppliers, and it has no customers.  If
     critical services such as utilities, communications or
     banking are affected, the intended operations of Comstock
     Industries, Inc. can be expected to be disrupted.

     Cost of Y2K Compliance

            Comstock Industries, Inc. has not spent any funds
     on Y2K compliance, nor does it expect to have to spend any
     material amount of funds on Y2K compliance in the future.



                   PART II.  OTHER INFORMATION

     ITEM 1.        LEGAL PROCEEDINGS.  None.

     ITEM 2.        CHANGES IN SECURITIES.  None.

     ITEM 3.        DEFAULTS UPON SENIOR SECURITIES.  None.

     ITEM 4.        SUBMISSION OF MATTERS TO A VOTE OF SECURITY
                    HOLDERS.  None.

     ITEM 5.        OTHER EVENTS.  None.

     ITEM 6. EXHIBITS, LISTS AND REPORTS ON FORM 8-K:

     (a)    Exhibits.

     
                                        
                  Description                 Location
     Exhibit
     Number

     27           Financial Data Schedule     Filed Electronically Herewith
     


     (b)    Reports on Form 8-K.  No reports on Form 8-K were
            filed during the quarter ended October 31, 1999.



                                SIGNATURES

            In accordance with the requirements of Section 13
     or 15(d) of the Securities and Exchange Act of 1934,
     Comstock Industries, Inc. caused this report to be signed
     on its behalf by the undersigned, thereunto duly authorized.


                                     COMSTOCK INDUSTRIES, INC.



                                     By: /s/ J. Antonio Martinez
                                     J. Antonio Martinez, President
                                     August 11, 2000