<SEC-DOCUMENT>0000000000-07-053879.txt : 20120808
<SEC-HEADER>0000000000-07-053879.hdr.sgml : 20120808
<ACCEPTANCE-DATETIME>20071102144414
<PRIVATE-TO-PUBLIC>
ACCESSION NUMBER:		0000000000-07-053879
CONFORMED SUBMISSION TYPE:	UPLOAD
PUBLIC DOCUMENT COUNT:		1
FILED AS OF DATE:		20071102

FILED FOR:		

	COMPANY DATA:	
		COMPANY CONFORMED NAME:			GABELLI EQUITY TRUST INC
		CENTRAL INDEX KEY:			0000794685
		IRS NUMBER:				222736509
		STATE OF INCORPORATION:			MD
		FISCAL YEAR END:			1231

	FILING VALUES:
		FORM TYPE:		UPLOAD

	BUSINESS ADDRESS:	
		STREET 1:		ONE CORP CENTER
		CITY:			RYE
		STATE:			NY
		ZIP:			10580
		BUSINESS PHONE:		9149215070
</SEC-HEADER>
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>




								November 2, 2007


David Joire, Esq.
Willkie Farr & Gallagher LLP
1875 K Street, NW
Washington, DC  20006


      RE:	Gabelli Equity Trust Inc.
      333-146634; 811-04700

Dear Mr. Joire:

	We have reviewed the registration statement on Form N-2 for
the
Gabelli Equity Trust Inc., filed with the Securities and Exchange
Commission on October 11, 2007.  We have the following comments:


PROSPECTUS


Financial Highlights

1. Under the heading, "Distributions to Common Shareholders," it
shows distributions from net investment income, net realized gain
on
investments, and return of capital.  Please explain to us how the
Fund ensures compliance with Rule 19(a)-1 of the Investment
Company
Act of 1940.

Description of Capital Stock

2. Under the heading, "Preferred Stock," it states that
"currently,
24,000,000 shares of the Fund`s capital stock have been classified
by
the Board as preferred stock, par value $0.001 per share."  Please
clarify whether the 24,000,000 shares include the preferred shares
being registered with this registration statement.


STATEMENT OF ADDITIONAL INFORMATION

Ownership of Shares in the Fund

3. Please move the information under this heading above the
section
titled "Portfolio Holdings Information" so that the information on
Portfolio Mangers` ownership of fund shares is included under
"Portfolio Manager Information."


GENERAL

4. We note that portions of the filing are incomplete.  We may
have
additional comments on such portions when you complete them in a
pre-
effective amendment, on disclosures made in response to this
letter,
on information supplied supplementally, or on exhibits added in
any
pre-effective amendments.
5. If you intend to omit certain information from the form of
prospectus included with the registration statement that is
declared
effective in reliance on Rule 430A under the Securities Act,
please
identify the omitted information to us supplementally, preferable
before filing the Fund`s final pre-effective amendment.
6. Response to this letter should be in the form of a pre-
effective
amendment filed pursuant to Rule 472 of the Securities Act.  Where
no
change will be made in the filing in response to a comment, please
indicate this fact in a supplemental letter and briefly state the
basis for your position.


TANDY LETTER

   We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the Fund and its management are in
possession of all facts relating to the Fund`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

   Notwithstanding our comments, please furnish a letter
acknowledging that
* Should the Commission or the staff, acting pursuant to delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;
* The action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the Fund from its full responsibility for the adequacy and
accuracy of the disclosure in the filing; and
* The Fund may not assert this action as defense in any proceeding
initiated by the Commission or any person under the federal
securities laws of the United States.

   In addition, please be advised that the Division of Enforcement
has access to all information you provide to the staff of the
Division of Investment Management in connection with our review of
your filing or in response to our comments on your filing.

   We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities.  We will act on the request and, pursuant to
delegated authority, grant acceleration of the effective date.


			*		*		*		*
     If you have any questions about these comments, please call
me
at 202-551-6957.

								Sincerely,



								Laura E. Hatch
								Staff Accountant
</TEXT>
</DOCUMENT>
</SEC-DOCUMENT>
