October 10, 2006

Aaron D. Wasserman, Esq.
Willkie Farr & Gallagher LLP
787 7th Avenue
New York, New York 10019

RE:	Gabelli Equity Trust, Inc.
      333-137298; 811-04700

Dear Mr. Wasserman:

	We have reviewed the registration statement on Form N-2 filed
on
behalf of the Gabelli Equity Trust, Inc. on September 13, 2006,
for
the purpose of registering shares of two new series of the Fund`s
preferred stock, the Series F Cumulative Preferred Stock and the
Series G Auction Rate Preferred Stock.  Your letter that
accompanied
this filing stated that the description of the mechanics of the
preferred stock offering is virtually identical to that of The
Gabelli Dividend and Income Trust (File Nos. 333-126480 and 811-
21423) which was declared effective on November 1, 2005.  In
addition, the description of the Fund is based upon the Fund`s
rights
offering filed on Form N-2 (File Nos. 333-127724 and 811-04700),
the
registration statement of which was declared effective on
September
27, 2005.  You also noted that an almost identical description of
the
Fund was also recently reviewed on the Fund`s Form N-14, the
registration statement of which was declared effective on August
18,
2005 (File Nos. 333-126111 and 811-04700).  You requested
selective
review of the registration statement and we have the following
comments:

PROSPECTUS

Investment Objectives

1. On page 2, please state the minimum rating for preferred stock
and
convertible bonds in which the Fund may invest.

Common Stock Distribution

2. On page 4, it states that "the Fund has adopted a managed
distribution policy, which may be changed at any time by the Board
of
Directors, of paying a minimum annual distribution of 10% of the
average net asset value of the Fund to common stockholders."
Please
add disclosure that the distribution or return of capital should
not
be confused with yield and include the risks involved with this
type
of distribution.

Use of Proceeds

3. On page 9, it states that "the Fund intends to use the net
proceeds to redeem [all] shares of Series B Preferred of which
there
are 4,950,000 shares outstanding with a liquidation rate of $25
per
share, which were redeemable beginning on June 20, 2006."  Please
state the time limit (i.e. how long it will take to redeem all
shares
of Series B Preferred).

Special Characteristics and Risks

4. On page 12 it states that the Fund may invest up to 10% of its
total assets in fixed-income securities rated in the lower rating
categories of recognized statistical rating agencies."  Please
state
the minimum rating in which the Fund may invest.

Management and Fees

5. On page 13 it states that "the Investment Adviser has agreed to
reduce the management fee...during the fiscal year if the total
return of the net asset value of the common stock...does not
exceed
the stated dividend rate or corresponding swap rate of each
particular series of preferred stock."  Please clarify this
disclosure so that it can be easily understood by investors. Also
state whether the agreement to reduce the management fee is
contractual or voluntary.

Advisory Agreement

6. On page 35 it states that "a discussion regarding the basis of
the
Board of Directors` approval of the Advisory Agreement is
available
in the Fund`s semi-annual report to stockholders for the six
months
ended June 30, 2005."  Should the date be June 30, 2006?

Taxation of Stockholders

7. On page 57, please include a discussion of the tax consequences
to
a shareholder of selling shares of the Series G Auction Rate
Preferred Stock.  In addition, please include a discussion of the
tax
consequences to a shareholder of a mandatory redemption of the
Series
F Cumulative Preferred Stock or the Series G Auction Rate
Preferred
Stock.

Additional Information

8. On page 67 it states that "the Board of Directors of the Fund
has
approved, subject to shareholder and other regulatory approvals,
the
contribution of a portion of the Fund`s assets to a newly formed
non-
diversified, closed-end investment company, The Gabelli Global
Healthcare & WellnessRx Trust (the "Healthcare & WellnessRx
Trust").
All of the Healthcare & WellnessRx Trust`s common stock would then
be
distributed to the common stockholders of the Fund."  Please
explain
how the transaction mentioned above will be structured.  For
example,
will the Gabelli Equity Trust hold shares of the Gabelli Global
Healthcare & WellnessRx Trust?  If so, for how long (i.e. what is
the
time lag between the contribution of the Fund`s assets and the
distribution of shares of the new fund to shareholders)?  Please
explain to us in detail how this arrangement complies with Section
12(d) of the 1940 Act.

Special Note Regarding Forward-Looking Statements

9. On page 69, this section attempts to limit liability for
forward-
looking statements.  Please delete attempts to limit liability.
Statements relating to investment companies are excluded from the
safe harbor for forward-looking statements.  (See Section 21E (b)
(2)
(B) of the Securities Exchange Act of 1934.)

GENERAL

10. 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.
11. 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.
12. 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

Aaron D. Wasserman, Esq.
September 9, 2005
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