<DOCUMENT>
<TYPE>EX-99
<SEQUENCE>8
<FILENAME>item5opinion.txt
<DESCRIPTION>EXHIBIT L
<TEXT>









                                                     June ___, 2002



The Gabelli Equity Trust Inc.
One Corporate Center
Rye, New York 10580-1434

Ladies and Gentlemen:

         In connection with the registration under the Securities Act of
1933 (the "Act") of the Series C Auction Rate Cumulative Preferred Stock,
$.001 par value per share (the "Series C Preferred Stock"), of The Gabelli
Equity Trust Inc., a Maryland corporation (the "Fund"), on its Registration
Statement on Form N-2 (Registration Nos. 333-86554 and 811-4700) filed with
the Securities and Exchange Commission (together with all amendments
thereto, the "Registration Statement"), we have examined such corporate
records, certificates and documents as we deemed necessary for the purpose
of this opinion. Based on that examination, we advise you that in our
opinion the Series C Preferred Stock to be offered by the Fund, when issued
and sold under the circumstances contemplated in the Registration
Statement, will be legally issued, fully paid and non-assessable.

         We hereby consent to the filing of this opinion as an exhibit to
the Registration Statement. In giving our consent, we do not thereby admit
that we are in the category of persons whose consent is required under
Section 7 of the Act or the rules and regulations of the Securities and
Exchange Commission thereunder. The opinion expressed herein is limited to
the matters set forth in this letter and no other opinion should be
inferred beyond the matters expressly stated.

                                            Very truly yours,

                                            Miles & Stockbridge P.C.


                                            By:  J. W. Thompson Webb
                                               ----------------------------
                                               Principal


</TEXT>
</DOCUMENT>
