March 26, 2008


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

      RE:	The Gabelli Utility Trust
      333-149415; 811-09243

Dear Mr. Joire:

	We have reviewed the registration statement on Form N-2 for
The
Gabelli Utility Trust, filed with the Securities and Exchange
Commission on February 27, 2008.  We have the following comments:

PROSPECTUS

Prospectus Summary

1. The registration statement pertains to a shelf offering for
preferred stock but does not disclose the material terms of these
securities.  Please revise the disclosure to include the material
terms of the subject securities.

2. Under the heading, "Investment Objective and Policies," the
disclosure states that "[t]he Fund will invest 80% of its assets,
under normal market conditions, in common stocks and other
securities
of foreign and domestic companies involved in providing products,
services, or equipment for (i) the generation or distribution of
electricity, gas, and water and (ii) telecommunications services
or
infrastructure operations (collectively, the "Utilities
Industry")."
Please provide an asset and/or revenue test for issues deemed to
be
in this industry (i.e., 50% of its assets devoted to or 50% of its
revenues derived from the utilities industry).

3. Under the heading, "Dividends and Distributions," the
disclosure
states that "[f]or the fiscal year ended December 31, 2007, the
Fund
made distributions of $0.72 per common share, of which $0.23762
per
share is deemed a return of capital."  In addition, under the
heading
"Common Share Distribution Policy Risk," the disclosure states
that a
"portion of the distributions to holders of common shares during
four
of the eight fiscal years since the Fund`s inception has
constituted
a return of capital."  As is stated in the disclosure, a return of
capital has "the effect of decreasing the asset coverage per share
with respect to the Fund`s preferred shares."  Please explain to
us
whether the Board has considered changing the managed distribution
policy for the Fund.  In addition, please disclose the tax
consequences to shareholders of receiving return of capital
distributions.

4. Under the heading, "Use of Proceeds," please disclose how long
it
will take the Fund to invest the proceeds from the offering.

5. Under the heading "Repurchase of Common Shares," the disclosure
states that "[t]he Fund is authorized, subject to maintaining
required asset coverage on its preferred shares, to repurchase its
common shares in the open market when the common shares are
trading
at a discount of 10% or more...from net asset value."  Please make
it
clear whether the Fund will repurchase its common shares in the
open
market when the common shares are trading at a discount of 10% or
whether the Fund reserves the freedom of action to repurchase its
common shares.  In addition, please discuss how much of the
outstanding common shares the Fund will repurchase (i.e., until
the
discount falls to x%).

Financial Highlights

6. Pursuant to Item 4 of Form N-2, the third line item under the
heading "Distributions to Common Shareholders" should be "Return
of
Capital" instead of "Paid-in capital."  In addition, please
explain
to us how the net asset value total return and the investment
total
return are calculated.  How does the distribution of return of
capital affect each total return calculation?

Regulatory Matters

7. The disclosure states, "In February 2007, the Investment
Adviser
made an offer of settlement to the Staff for communication to the
SEC
for its consideration to resolve this matter.  This offer of
settlement is subject to final agreement regarding the specific
language of the SEC`s administrative order and other settlement
documents.  Since these discussions are ongoing, the Investment
Adviser cannot determine whether they will ultimately result in a
settlement of this matter and, if so, what the terms of the
settlement might be."  Please update the disclosure as applicable
and
provide more specific information concerning the settlement offer.


STATEMENT OF ADDITIONAL INFORMATION

Investment Restrictions

8. The first restriction states that the Fund may not "invest 25%
or
more of its total assets, taken at market value at the time of
each
investment, in the securities of issuers in any particular
industry
other than the Utility Industry."  Please restate the restriction
to
make it clear that the Fund will invest 25% or more of its total
assets in the Utility Industry.


GENERAL

9. 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.

10. 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.

11. 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