Gabelli Value 25 Fund

Filed: 5 Sep 19, 4:24pm



Washington, D.C. 20549




Investment Company Act file number          811-05848                   

           The Gabelli Value 25 Fund Inc.        

(Exact name of registrant as specified in charter)

One Corporate Center

                               Rye, New York 10580-1422                             

(Address of principal executive offices) (Zip code)

Bruce N. Alpert

Gabelli Funds, LLC

One Corporate Center

                               Rye, New York 10580-1422                             

(Name and address of agent for service)

Registrant’s telephone number, including area code: 1-800-422-3554

Date of fiscal year end:  December 31

Date of reporting period:  June 30, 2019

FormN-CSR is to be used by management investment companies to file reports with the Commission not later than 10 days after the transmission to stockholders of any report that is required to be transmitted to stockholders under Rule30e-1 under the Investment Company Act of 1940 (17 CFR270.30e-1). The Commission may use the information provided on FormN-CSR in its regulatory, disclosure review, inspection, and policymaking roles.

A registrant is required to disclose the information specified by FormN-CSR, and the Commission will make this information public. A registrant is not required to respond to the collection of information contained inForm N-CSR unless the Form displays a currently valid Office of Management and Budget (“OMB”) control number. Please direct comments concerning the accuracy of the information collection burden estimate and any suggestions for reducing the burden to Secretary, Securities and Exchange Commission, 450 Fifth Street, NW, Washington, DC 20549-0609. The OMB has reviewed this collection of information under the clearance requirements of 44 U.S.C. § 3507.

Item 1.

Reports to Stockholders.

The Report to Shareholders is attached herewith.


The Gabelli Value 25 Fund Inc.

Semiannual Report — June 30, 2019

(Y)our Portfolio Management Team




Mario J. Gabelli, CFA


Christopher J. Marangi

Chief Investment Officer


Co-Chief Investment Officer

  BA, Williams College
  MBA, Columbia
  Business School

To Our Shareholders,

For the six months ended June 30, 2019, the net asset value (NAV) per Class A Share of The Gabelli Value 25 Fund increased 15.3% compared with increases of 18.5% and 15.4% for the Standard & Poor’s (S&P) 500 Index and the Dow Jones Industrial Average, respectively. Other classes of shares are available. See page 2 for performance information for all classes of shares.

Enclosed are the financial statements, including the schedule of investments, as of June 30, 2019.


Beginning on January 1, 2021, as permitted by regulations adopted by the Securities and Exchange Commission, paper copies of the Fund’s annual and semiannual shareholder reports will no longer be sent by mail, unless you specifically request paper copies of the reports. Instead, the reports will be made available on the Fund’s website (, and you will be notified by mail each time a report is posted and provided with a website link to access the report. If you already elected to receive shareholder reports electronically, you will not be affected by this change and you need not take any action. To elect to receive all future reports on paper free of charge, please contact your financial intermediary, or, if you invest directly with the Fund, you may call800-422-3554 or send an email request to

Comparative Results



Average Annual Returns through June 30, 2019 (a) (Unaudited)

     Six Months 1 Year 5 Year 10 Year 15 Year Since

Class A (GABVX)

   15.28  4.09  3.60  12.22  6.82  9.91 

With sales charge (b)

   8.65   (1.90  2.38   11.55   6.40   9.69  

S&P 500 Index

   18.54   10.42   10.71   14.70   8.75   9.74  

Dow Jones Industrial Average

   15.36   12.14   12.24   14.97   9.14   10.69  

Nasdaq Composite Index

   21.30   7.77   13.72   16.69   10.16   10.34  


   15.26   4.16   3.61   12.22   6.83   9.92  

Class C (GVCCX)

   14.90   3.38   2.83   11.39   6.02   9.39  

With contingent deferred sales charge (c)

   13.90   2.38   2.83   11.39   6.02   9.39  

Class I (GVCIX)

   15.47   4.58   3.96   12.56   7.06   10.04  




In the current prospectuses dated April 30, 2019, the gross expense ratios for Class AAA, A, C, and I Shares are 1.44%, 1.44%, 2.19%, and 1.19% respectively, and the net expense ratios for these share classes after contractual reimbursements by Gabelli Funds, LLC, (the Adviser) are 1.44%, 1.44%, 2.19%, and 1.00%, respectively. See page 9 for the expense ratios for the six months ended June 30, 2019. The contractual reimbursement for Class I Shares is in effect through April 30, 2020. Class AAA and Class I Shares do not have a sales charge. The maximum sales charge for Class A and Class C Shares is 5.75% and 1.00%, respectively.


(a)  Returns represent past performance and do not guarantee future results. Total returns and average annual returns reflect changes in share price, reinvestment of distributions, and are net of expenses. Investment returns and the principal value of an investment will fluctuate. When shares are redeemed, they may be worth more or less than their original cost. Current performance may be lower or higher than the performance data presented. Visit for performance information as of the most recent month end. Returns would have been lower had the Adviser not reimbursed certain expenses of the Fund. The Fund imposes a 2% redemption fee on shares sold or exchanged within seven days of purchase. Performance returns for periods of less than one year are not annualized. Investors should carefully consider the investment objectives, risks, charges, and expenses of the Fund before investing. The prospectuses contain information about these and other matters and should be read carefully before investing. To obtain a prospectus, please visit our website at Class A Share NAVs are used to calculate performance for the periods prior to the issuance of Class AAA Shares on April 30, 2010, Class C Shares on March 15, 2000, and Class I Shares on January 11, 2008. The actual performance of the Class C Shares would have been lower due to the additional fees and expenses associated with this class of shares. The actual performance of the Class AAA Shares and Class I Shares would have been higher due to lower expenses associated with these classes of shares. The S&P 500 Index is a market capitalization weighted index of 500 large capitalization stocks commonly used to represent the U.S. equity market. The Dow Jones Industrial Average and the Nasdaq Composite Index are unmanaged indicators of stock market performance. Dividends are considered reinvested, except for the Nasdaq Composite Index. You cannot invest directly in an index.

(b)  Performance results include the effect of the maximum 5.75% sales charge at the beginning of the period.

(c)  Assuming payment of the 1% maximum contingent deferred sales charge imposed on redemptions made within one year of purchase.




The Gabelli Value 25 Fund Inc.

Disclosure of Fund Expenses (Unaudited)


For the Six Month Period from January 1, 2019 through June 30, 2019


 Expense Table


We believe it is important for you to understand the impact of fees and expenses regarding your investment. All mutual funds have operating expenses. As a shareholder of a fund, you incur ongoing costs, which include costs for portfolio management, administrative services, and shareholder reports (like this one), among others. Operating expenses, which are deducted from a fund’s gross income, directly reduce the investment return of a fund. When a fund’s expenses are expressed as a percentage of its average net assets, this figure is known as the expense ratio. The following examples are intended to help you understand the ongoing costs (in dollars) of investing in your Fund and to compare these costs with those of other mutual funds. The examples are based on an investment of $1,000 made at the beginning of the period shown and held for the entire period.

The Expense Table below illustrates your Fund’s costs in two ways:

Actual Fund Return:This section provides information about actual account values and actual expenses. You may use this section to help you to estimate the actual expenses that you paid over the period after any fee waivers and expense reimbursements. The “Ending Account Value” shown is derived from the Fund’sactualreturn during the past six months, and the “Expenses Paid During Period” shows the dollar amount that would have been paid by an investor who started with $1,000 in the Fund. You may use this information, together with the amount you invested, to estimate the expenses that you paid over the period.

To do so, simply divide your account value by $1,000 (for example, an $8,600 account value divided by $1,000 = 8.6), then multiply the result by the number given for your Fund under the heading “Expenses Paid During Period” to estimate the expenses you paid during this period.

Hypothetical 5% Return:This section provides information about hypothetical account values and


hypothetical expenses based on the Fund’s actual expense ratio. It assumes a hypothetical annualized return of 5% before expenses during the period shown. In this case – because the hypothetical return used isnotthe Fund’s actual return – the results do not apply to your investment and you cannot use the hypothetical account value and expense to estimate the actual ending account balance or expenses you paid for the period. This example is useful in making comparisons of the ongoing costs of investing in the Fund and other funds. To do so, compare this 5% hypothetical example with the 5% hypothetical examples that appear in shareholder reports of other funds.

Please note that the expenses shown in the table are meant to highlight your ongoing costs only and do not reflect any transactional costs such as sales charges (loads), redemption fees, or exchange fees, if any, which would be described in the Prospectus. If these costs were applied to your account, your costs would be higher. Therefore, the 5% hypothetical return is useful in comparing ongoing costs only, and will not help you determine the relative total costs of owning different funds.




Account Value




Account Value








Paid During



The Gabelli Value 25 Fund Inc.


Actual Fund Return



Class AAA

  $1,000.00   $1,152.60   1.43%   $  7.63 

Class A

  $1,000.00   $1,152.80   1.43%   $  7.63 

Class C

  $1,000.00   $1,149.00   2.18%   $11.62 

Class I

  $1,000.00   $1,154.70   1.00%   $  5.34 

Hypothetical 5% Return


Class AAA

  $1,000.00   $1,017.70   1.43%   $  7.15 

Class A

  $1,000.00   $1,017.70   1.43%   $  7.15 

Class C

  $1,000.00   $1,013.98   2.18%   $10.89 

Class I

  $1,000.00   $1,019.84   1.00%   $  5.01 



Expenses are equal to the Fund’s annualized expense ratio for the last six months multiplied by the average account value over the period, multiplied by the number of days in the most recent fiscal half year (181 days), then divided by 365.




Summary of Portfolio Holdings (Unaudited)

The following table presents portfolio holdings as a percent of net assets as of June 30, 2019:

The Gabelli Value 25 Fund Inc.






Financial Services


Cable and Satellite


Food and Beverage


Environmental Services




Consumer Products


Diversified Industrial


Metals and Mining




Automotive: Parts and Accessories


Energy and Utilities


Business Services


Equipment and Supplies


Hotels and Gaming






Specialty Chemicals




Communications Equipment


Computer Software and Services


Wireless Communications


Real Estate


Building and Construction


U.S. Treasury Bills


Other Assets and Liabilities (Net)














The Fund files a complete schedule of portfolio holdings with the Securities and Exchange Commission (the SEC) for the first and third quarters of each fiscal year on FormN-PORT. Shareholders may obtain this information at or by calling the Fund at800-GABELLI(800-422-3554). The Fund’s FormN-PORT is available on the SEC’s website at and may also be reviewed and copied at the SEC’s Public Reference Room in Washington, DC. Information on the operation of the Public Reference Room may be obtained by calling800-SEC-0330.

Proxy Voting

The Fund files FormN-PX with its complete proxy voting record for the twelve months ended June 30, no later than August 31 of each year. A description of the Fund’s proxy voting policies, procedures, and how the Fund voted proxies relating to portfolio securities is available without charge, upon request, by (i) calling800-GABELLI(800-422-3554); (ii) writing to The Gabelli Funds at One Corporate Center, Rye, NY 10580-1422; or (iii) visiting the SEC’s website at



The Gabelli Value 25 Fund Inc.

Schedule of Investments — June 30, 2019 (Unaudited)











  Aerospace — 3.4%   

Aerojet Rocketdyne Holdings Inc.†

  $1,675,613  $ 10,968,650 

Rolls-Royce Holdings plc

   1,048,237   1,494,177 

Rolls-Royce Holdings plc, Cl. C†

   12,826   12,624 
     2,736,676   12,475,451 
  Automotive — 1.2%   

Navistar International Corp.†

   3,319,799   4,375,150 
  Automotive: Parts and Accessories — 3.3%



Garrett Motion Inc.†

   651,142   767,500 

Genuine Parts Co.

   2,039,498   9,218,620 

O’Reilly Automotive Inc.†

   804,306   2,400,580 
     3,494,946   12,386,700 
  Broadcasting — 10.2%   

CBS Corp., Cl. A, Voting

   9,055,012   24,719,760 

Liberty Broadband Corp., Cl. A†

   314,951   719,880 

Liberty Broadband Corp., Cl. C†

   1,147,346   5,627,880 

Liberty Media Corp.- Liberty SiriusXM, Cl. C†

   322,039   3,608,100 

MSG Networks Inc., Cl. A†

   76,944   3,442,840 
       10,916,292   38,118,460 
  Building and Construction — 0.4%



Johnson Controls International plc

   629,811   1,652,400 
  Business Services — 2.6%



Macquarie Infrastructure Corp.

   2,300,865   3,243,200 

Mastercard Inc., Cl. A

   493,639   6,348,720 
     2,794,504   9,591,920 
  Cable and Satellite — 7.4%   

AMC Networks Inc., Cl. A†

   0   4,141,240 

Comcast Corp., Cl. A

   1,887,027   5,496,400 

DISH Network Corp., Cl. A†

   2,662,878   5,185,350 

EchoStar Corp., Cl. A†

   2,126,363   3,767,200 

Liberty Global plc, Cl. A†

   2,175,885   3,967,530 

Liberty Global plc, Cl. C†

   448,934   1,193,850 

Rogers Communications Inc., Cl. B

   230,474   3,799,920 
     9,531,561   27,551,490 
  Communications Equipment — 0.7%



Loral Space & Communications Inc.†

   3,534,456   2,415,700 

Computer Software and Services — 0.6%



Hewlett Packard Enterprise Co.

   2,123,644   2,317,250 
  Consumer Products — 4.7%



Edgewell Personal Care Co.†

   975,707   1,266,650 

Energizer Holdings Inc.

   1,123,056   1,932,000 








Swedish Match AB

  $4,929,082  $ 14,352,557 
     7,027,845   17,551,207 
  Diversified Industrial — 4.5%



Ampco-Pittsburgh Corp.†

   175,012   141,050 

Crane Co.

   2,404,806   7,759,920 

Honeywell International Inc.

   1,077,210   8,729,500 
     3,657,028   16,630,470 
  Electronics — 5.8%   

Resideo Technologies Inc.†

   1,173,907   1,446,720 

Sony Corp., ADR

   6,535,947   20,222,540 
     7,709,854   21,669,260 
  Energy and Utilities — 3.0%   

National Fuel Gas Co.

   9,406,084   11,235,750 
  Entertainment — 16.5%   

Discovery Inc., Cl. A†

   369,758   1,228,000 

Discovery Inc., Cl. C†

   2,488,263   4,978,750 

Fox Corp., Cl. A

   1,662,000   1,465,600 

Fox Corp., Cl. B

   1,384,259   1,242,020 

Grupo Televisa SAB, ADR

   3,331,546   2,741,312 

Liberty Media Corp.- Liberty Braves, Cl. A†

   285,275   444,800 

Liberty Media Corp.- Liberty Braves, Cl. C†

   1,849,967   2,993,909 

The Madison Square Garden Co., Cl. A†

   321,538   18,056,130 

The Walt Disney Co.

   2,238,008   6,842,360 

Viacom Inc., Cl. A

   18,927,159   21,585,300 
       32,857,773   61,578,181 
  Environmental Services — 6.0%



Republic Services Inc.

   2,261,327   15,595,200 

Waste Connections Inc.

   2,235,545   6,690,600 
     4,496,872   22,285,800 
  Equipment and Supplies — 2.3%



CIRCOR International Inc.†

   1,038,349   3,956,000 

Flowserve Corp.

   528,443   4,742,100 
     1,566,792   8,698,100 
  Financial Services — 9.5%   

American Express Co.

   3,325,430   15,923,760 

H&R Block Inc.

   1,496,069   2,490,500 

Legg Mason Inc.

   1,311,403   2,220,240 

The Bank of New York Mellon Corp.

   7,325,659   10,375,250 

Wells Fargo & Co.

   2,798,711   4,258,800 
     16,257,272   35,268,550 
  Food and Beverage — 6.1%



Diageo plc, ADR

   3,130,706   14,474,880 


See accompanying notes to financial statements.



The Gabelli Value 25 Fund Inc.

Schedule of Investments (Continued) — June 30, 2019 (Unaudited)









  COMMON STOCKS (Continued)


  Food and Beverage (Continued)



Fomento Economico Mexicano SAB de CV, ADR

  $392,782  $3,289,500 

Mondelēz International Inc., Cl. A

       2,285,660   4,851,000 
     5,809,148   22,615,380 
  Hotels and Gaming — 2.0%



Ryman Hospitality Properties Inc., REIT

   2,422,453   7,557,588 
  Machinery — 1.9%   

CNH Industrial NV

   1,331,785   1,888,888 

CNH Industrial NV, Borsa Italiana

   990,523   1,127,981 

Xylem Inc.

   1,079,467   4,098,360 
     3,401,775   7,115,229 
  Metals and Mining — 3.9%   

Newmont Goldcorp Corp.

   7,448,987   14,657,070 
  Real Estate — 0.6%   

Griffin Industrial Realty Inc.

   1,041,210   2,163,420 
  Specialty Chemicals — 1.2%



Ashland Global Holdings Inc.

   1,180,714   1,599,400 

International Flavors & Fragrances Inc.

   1,501,989   2,756,710 
     2,682,703   4,356,110 







  Telecommunications — 0.9%



Telephone & Data Systems Inc.

  $2,506,714  $3,435,200 
  Wireless Communications — 0.6%



United States Cellular Corp.†

   2,167,350   2,233,500 


   149,541,549   369,935,336 





U.S. Treasury Bills, 2.191% to 2.323%††, 08/29/19 to 09/05/19

   1,006,129   1,006,418 



  $150,547,678   370,941,754 




Other Assets and Liabilities (Net) — 0.4%




NET ASSETS — 100.0%







Non-income producing security.


Represents annualized yields at dates of purchase.


American Depositary Receipt


Real Estate Investment Trust



See accompanying notes to financial statements.



The Gabelli Value 25 Fund Inc.


Statement of Assets and Liabilities

June 30, 2019 (Unaudited)




Investments, at value (cost $150,547,678)




Receivable for investments sold


Receivable for Fund shares sold


Receivable from Adviser


Dividends receivable


Prepaid expenses





Total Assets







Payable for Fund shares redeemed


Payable for investment advisory fees


Payable for distribution fees


Payable for accounting fees


Payable for shareholder communications expenses


Payable for shareholder services fees


Other accrued expenses





Total Liabilities





Net Assets
(applicable to 25,041,197 shares outstanding)





Net Assets Consist of:


Paid-in capital


Total distributable earnings





Net Assets





Shares of Capital Stock, each at $0.001 par value:


Class AAA:


Net Asset Value, offering, and redemption price per share ($4,112,199 ÷ 276,372 shares outstanding; 50,000,000 shares authorized)


Class A:


Net Asset Value and redemption price per share ($308,976,126 ÷ 20,674,921 shares outstanding; 100,000,000 shares authorized)


Maximum offering price per share (NAV ÷ 0.9425, based on maximum sales charge of 5.75% of the offering price)


Class C:


Net Asset Value and offering price per share ($5,037,148 ÷ 447,273 shares outstanding; 50,000,000 shares authorized)


Class I:


Net Asset Value, offering, and redemption price per share ($54,399,699 ÷ 3,642,631 shares outstanding; 50,000,000 shares authorized)




Redemption price varies based on the length of time held.

Statement of Operations

For the Six Months Ended June 30, 2019 (Unaudited)


Investment Income:


Dividends (net of foreign withholding taxes of $134,143)







Total Investment Income







Investment advisory fees


Distribution fees - Class AAA


Distribution fees - Class A


Distribution fees - Class C


Shareholder services fees


Shareholder communications expenses


Directors’ fees


Registration expenses


Legal and audit fees


Custodian fees


Accounting fees


Interest expense


Miscellaneous expenses





Total Expenses







Expense reimbursements (See Note 3)


Expenses paid indirectly by broker (See Note 6)


Custodian fee credits





Total Reimbursements and Credits





Net Expenses





Net Investment Income





Net Realized and Unrealized Gain/(Loss) on Investments and Foreign Currency:


Net realized gain on investments


Net realized loss on foreign currency transactions





Net realized gain on investments and foreign currency transactions





Net change in unrealized appreciation/depreciation:


on investments


on foreign currency translations





Net change in unrealized appreciation/depreciation on investments and foreign currency translations





Net Realized and Unrealized Gain/(Loss) on Investments and Foreign Currency





Net Increase in Net Assets Resulting from Operations






See accompanying notes to financial statements.



The Gabelli Value 25 Fund Inc.

Statement of Changes in Net Assets




   Six Months Ended
June 30,  2019
 Year Ended
December 31, 2018



Net investment income

   $763,305  $313,203

Net realized gain on investments and foreign currency transactions

    17,802,584   33,216,788

Net change in unrealized appreciation/depreciation on investments and foreign currency translations

    32,917,575   (63,989,762)







Net Increase/(Decrease) in Net Assets Resulting from Operations

    51,483,464   (30,459,771)







Distributions to Shareholders:


Accumulated earnings


Class AAA


Class A


Class C


Class I








Total Distributions to Shareholders








Capital Share Transactions:


Class AAA

    (250,550)   (144,439)

Class A

    (15,148,424)   (30,365,984)

Class C

    (2,442,509)   (526,197)

Class I

    (1,097,583)   (3,944,470)

Class T*








Net Decrease in Net Assets from Capital Share Transactions

    (18,939,066)   (34,982,208)







Redemption Fees

    4,142   7







Net Increase/(Decrease) in Net Assets

    32,548,540   (96,200,703)

Net Assets:


Beginning of year

    339,976,632   436,177,335







End of period

   $372,525,172  $339,976,632









Class T Shares were liquidated on September 21, 2018.



See accompanying notes to financial statements.



The Gabelli Value 25 Fund Inc.

Financial Highlights


Selected data for a share of capital stock outstanding throughout each period:


     Income (Loss)
from Investment  Operations
 Distributions        Ratios to Average Net Assets  /
Supplemental Data

Year Ended

December 31

  Net Asset
of Year
Gain (Loss)
 Total from
Gain on
Fees (a)(b)
  Net Asset
End of

Net Assets,

End of Period

(in 000’s)











Net of




Class AAA



    $12.91   $ 0.02   $ 1.95   $ 1.97            $0.00    $14.88   15.3%   $    4,112       0.34%(d)   1.43%(d)   1.43%(d)(e)   2%


    15.41   0.00(b)   (1.27)   (1.27)   $ 0.00(b)   $(1.23   $(1.23   0.00    12.91   (8.2)   3,774   0.03   1.44   1.44(e)   2    


    14.61   0.01   1.85   1.86   (0.02)   (1.04)   (1.06)   0.00    15.41   12.7   4,542   0.09   1.41   1.41(e)   2


    14.07   0.07   1.57   1.64   (0.07)   (1.03)   (1.10)   0.00    14.61   11.6   4,103   0.48   1.40   1.40(e)   2


    18.23   0.01   (1.72)   (1.71)   (0.01)   (2.44)   (2.45)       14.07   (9.5)   4,492   0.05   1.39   1.39(e)   3


    19.71   0.02   0.34   0.36   (0.03)   (1.81)   (1.84)   0.00    18.23   1.7   7,321   0.12   1.38   1.38   23

Class A



    $12.96   $ 0.03   $ 1.95   $ 1.98            $0.00    $14.94   15.3%   $308,976   0.36%(d)   1.43%(d)   1.43%(d)(e)   2%


    15.48   0.00(b)   (1.29)   (1.29)   $ 0.00(b)   $(1.23   $(1.23   0.00    12.96   (8.2)   281,613   0.03   1.44   1.44(e)   2


    14.66   0.01   1.86   1.87   (0.01)   (1.04)   (1.05)   0.00    15.48   12.8   362,729   0.09   1.41   1.41(e)   2


    14.12   0.07   1.57   1.64   (0.07)   (1.03)   (1.10)   0.00    14.66   11.6   386,700   0.48   1.40   1.40(e)   2


    18.29   0.01   (1.73)   (1.72)   (0.01)   (2.44)   (2.45)       14.12   (9.5)   427,905   0.07   1.39   1.39 (e)   3


    19.78   0.02   0.33   0.35   (0.03)   (1.81)   (1.84)   0.00    18.29   1.6   563,876   0.11   1.38   1.38   23

Class C



    $  9.80   $(0.02   $ 1.48   $ 1.46            $0.00    $11.26   14.9%   $    5,037   (0.40)%(d)   2.18%(d)   2.18%(d)(e)   2%


    12.12   (0.09)   (1.00)   (1.09)      $(1.23   $(1.23   0.00    9.80   (8.9)   6,528   (0.72)   2.19   2.19(e)   2


    11.77   (0.08)   1.47   1.39      (1.04)   (1.04)   0.00    12.12   11.8   8,351   (0.67)   2.16   2.16 (e)   2


    11.55   (0.03)   1.28   1.25      (1.03)   (1.03)   0.00    11.77   10.8   11,171   (0.27)   2.15   2.15(e)   2


    15.55   (0.10)   (1.46)   (1.56)      (2.44)   (2.44)       11.55   (10.2)   13,317   (0.69)   2.14   2.14(e)   3


    17.18   (0.11)   0.29   0.18      (1.81)   (1.81)   0.00    15.55   0.9   19,395   (0.64)   2.13   2.13   23

Class I



    $12.93   $ 0.06   $ 1.94   $ 2.00            $0.00    $14.93   15.5%   $  54,400   0.80%(d)   1.18%(d)   1.00%(d)(e)(f)   2%


    15.45   0.07   (1.28)   (1.21)   $(0.08   $(1.23   $(1.31   0.00     12.93   (7.8)   48,062   0.47   1.19   1.00(e)(f)   2


    14.64   0.08   1.85   1.93   (0.08)   (1.04)   (1.12)   0.00    15.45   13.2   60,554   0.50   1.16   1.00(e)(f)   2


    14.10   0.12   1.57   1.69   (0.12)   (1.03)   (1.15)   0.00    14.64   11.9   46,922   0.79   1.15   1.13(e)(f)   2


    18.28   0.05   (1.73)   (1.68)   (0.06)   (2.44)   (2.50)       14.10   (9.3)   64,336   0.28   1.14   1.14(e)   3


    19.76   0.07   0.34   0.41   (0.08)   (1.81)   (1.89)   0.00    18.28   2.0   138,916   0.33   1.13   1.13   23



Total return represents aggregate total return of a hypothetical $1,000 investment at the beginning of the year and sold at the end of the year including reinvestment of distributions and does not reflect the applicable sales charges.


Per share amounts have been calculated using the average shares outstanding method.


Amount represents less than $0.005 per share.


For the six months ended June 30, 2019, unaudited.




The Fund received credits from a designated broker who agreed to pay certain Fund operating expenses. For the six months ended June 30, 2019 and the years ended December 31, 2018, 2017, 2016, and 2015, there was no impact on the expense ratios.


Under an expense reimbursement agreement with the Adviser, the Adviser reimbursed certain Class I expenses to the Fund. For the six months ended June 30, 2019 and the years ended December 31, 2018, 2017, and 2016, these reimbursements amounted to $47,383, $107,706, $87,199, and $11,790, respectively.


See accompanying notes to financial statements.



The Gabelli Value 25 Fund Inc.

Notes to Financial Statements (Unaudited)


1. Organization.The Gabelli Value 25 Fund Inc. was incorporated on July 20, 1989 in Maryland and commenced investment operations on September 29, 1989. The Fund is a diversifiedopen-end management investment company registered under the Investment Company Act of 1940, as amended (the 1940 Act). The Fund’s primary objective is long term capital appreciation.

2. Significant Accounting Policies.As an investment company, the Fund follows the investment company accounting and reporting guidance, which is part of U.S. generally accepted accounting principles (GAAP) that may require the use of management estimates and assumptions in the preparation of its financial statements. Actual results could differ from those estimates. The following is a summary of significant accounting policies followed by the Fund in the preparation of its financial statements.

New Accounting Pronouncements.To improve the effectiveness of fair value disclosure requirements, the Financial Accounting Standards Board recently issued Accounting Standard Update (ASU)2018-13, Fair Value Measurement Disclosure Framework – Changes to the Disclosure Requirements for Fair Value Measurement (ASU2018-13), which adds, removes, and modifies certain aspects relating to fair value disclosure. ASU2018-13 is effective for interim and annual reporting periods beginning after December 15, 2019; early adoption of the additions relating to ASU2018-13 is not required, even if early adoption is elected for the removals under ASU2018-13. Management has early adopted the removals set forth in ASU2018-13 in these financial statements and has not early adopted the additions set forth in ASU2018-13.

Security Valuation.Portfolio securities listed or traded on a nationally recognized securities exchange or traded in the U.S.over-the-counter market for which market quotations are readily available are valued at the last quoted sale price or a market’s official closing price as of the close of business on the day the securities are being valued. If there were no sales that day, the security is valued at the average of the closing bid and asked prices or, if there were no asked prices quoted on that day, then the security is valued at the closing bid price on that day. If no bid or asked prices are quoted on such day, the security is valued at the most recently available price or, if the Board of Directors (the Board) so determines, by such other method as the Board shall determine in good faith to reflect its fair market value. Portfolio securities traded on more than one national securities exchange or market are valued according to the broadest and most representative market, as determined by Gabelli Funds, LLC (the Adviser).

Portfolio securities primarily traded on a foreign market are generally valued at the preceding closing values of such securities on the relevant market, but may be fair valued pursuant to procedures established by the Board if market conditions change significantly after the close of the foreign market, but prior to the close of business on the day the securities are being valued. Debt obligations for which market quotations are readily available are valued at the average of the latest bid and asked prices. If there were no asked prices quoted on such day, the security is valued using the closing bid price, unless the Board determines that such amount does not reflect the securities’ fair value, in which case these securities will be fair valued as determined by the Board. Certain securities are valued principally using dealer quotations. Futures contracts are valued at the closing settlement price of the exchange or board of trade on which the applicable contract is traded. OTC futures and options on futures for which market quotations are readily available will be valued by quotations received from a pricing service or, if no quotations are available from a pricing service, by quotations obtained from one or more dealers in the instrument in question by the Adviser.



The Gabelli Value 25 Fund Inc.

Notes to Financial Statements (Unaudited) (Continued)



Securities and assets for which market quotations are not readily available are fair valued as determined by the Board. Fair valuation methodologies and procedures may include, but are not limited to: analysis and review of available financial andnon-financial information about the company; comparisons with the valuation and changes in valuation of similar securities, including a comparison of foreign securities with the equivalent U.S. dollar value American Depositary Receipt securities at the close of the U.S. exchange; and evaluation of any other information that could be indicative of the value of the security.

The inputs and valuation techniques used to measure fair value of the Fund’s investments are summarized into three levels as described in the hierarchy below:



Level 1 — quoted prices in active markets for identical securities;



Level 2 — other significant observable inputs (including quoted prices for similar securities, interest rates, prepayment speeds, credit risk, etc.); and



Level 3 — significant unobservable inputs (including the Board’s determinations as to the fair value of investments).

A financial instrument’s level within the fair value hierarchy is based on the lowest level of any input both individually and in the aggregate that is significant to the fair value measurement. The inputs or methodology used for valuing securities are not necessarily an indication of the risk associated with investing in those securities. The summary of the Fund’s investments in securities by inputs used to value the Fund’s investments as of June 30, 2019 is as follows:


   Valuation Inputs
   Level 1
Quoted Prices
 Level 2 Other Significant
Observable  Inputs
 Total Market Value
at  6/30/19



ASSETS (Market Value):


Common Stocks:



   $12,462,827  $12,624  $12,475,451

Other Industries (a)

    357,459,885      357,459,885

Total Common Stocks

    369,922,712   12,624   369,935,336

U.S. Government Obligations

       1,006,418   1,006,418


   $369,922,712  $1,019,042  $370,941,754



Please refer to the Schedule of Investments for the industry classifications of these portfolio holdings.

During the six months ended June 30, 2019, the Fund did not have transfers into or out of Level 3.



The Gabelli Value 25 Fund Inc.

Notes to Financial Statements (Unaudited) (Continued)



Additional Information to Evaluate Qualitative Information.

General.The Fund uses recognized industry pricing services – approved by the Board and unaffiliated withthe Adviser – to value most of its securities, and uses broker quotes provided by market makers of securities not valued by these and other recognized pricing sources. Several different pricing feeds are received to value domestic equity securities, international equity securities, preferred equity securities, and fixed income securities. The data within these feeds are ultimately sourced from major stock exchanges and trading systems where these securities trade. The prices supplied by external sources are checked by obtaining quotations or actual transaction prices from market participants. If a price obtained from the pricing source is deemed unreliable, prices will be sought from another pricing service or from a broker/dealer that trades that security or similar securities.

Fair Valuation.Fair valued securities may be common or preferred equities, warrants, options, rights, orfixed income obligations. Where appropriate, Level 3 securities are those for which market quotations are not available, such as securities not traded for several days, or for which current bids are not available, or which are restricted as to transfer. Among the factors to be considered to fair value a security are recent prices of comparable securities that are publicly traded, reliable prices of securities not publicly traded, the use of valuation models, current analyst reports, valuing the income or cash flow of the issuer, or cost if the preceding factors do not apply. A significant change in the unobservable inputs could result in a lower or higher value in Level 3 securities. The circumstances of Level 3 securities are frequently monitored to determine if fair valuation measures continue to apply.

The Adviser reports quarterly to the Board the results of the application of fair valuation policies and procedures. These may include backtesting the prices realized in subsequent trades of these fair valued securities to fair values previously recognized.

Foreign Currency Translations.The books and records of the Fund are maintained in U.S. dollars. Foreigncurrencies, investments, and other assets and liabilities are translated into U.S. dollars at current exchange rates. Purchases and sales of investment securities, income, and expenses are translated at the exchange rate prevailing on the respective dates of such transactions. Unrealized gains and losses that result from changes in foreign exchange rates and/or changes in market prices of securities have been included in unrealized appreciation/depreciation on investments and foreign currency translations. Net realized foreign currency gains and losses resulting from changes in exchange rates include foreign currency gains and losses between trade date and settlement date on investment securities transactions, foreign currency transactions, and the difference between the amounts of interest and dividends recorded on the books of the Fund and the amounts actually received. The portion of foreign currency gains and losses related to fluctuation in exchange rates between the initial purchase trade date and subsequent sale trade date is included in realized gain/(loss) on investments.

Foreign Securities.The Fund may directly purchase securities of foreign issuers. Investing in securities offoreign issuers involves special risks not typically associated with investing in securities of U.S. issuers. The risks include possible revaluation of currencies, the inability to repatriate funds, less complete financial information about companies, and possible future adverse political and economic developments. Moreover, securities of many foreign issuers and their markets may be less liquid and their prices more volatile than securities of comparable U.S. issuers.



The Gabelli Value 25 Fund Inc.

Notes to Financial Statements (Unaudited) (Continued)



Foreign Taxes.The Fund may be subject to foreign taxes on income, gains on investments, or currency repatriation,a portion of which may be recoverable. The Fund will accrue such taxes and recoveries as applicable, based upon its current interpretation of tax rules and regulations that exist in the markets in which it invests.

Restricted Securities.The Fund may invest up to 10% of its net assets in securities for which the marketsare restricted. Restricted securities include securities whose disposition is subject to substantial legal or contractual restrictions. The sale of restricted securities often requires more time and results in higher brokerage charges or dealer discounts and other selling expenses than does the sale of securities eligible for trading on national securities exchanges or in theover-the-counter markets. Restricted securities may sell at a price lower than similar securities that are not subject to restrictions on resale. Securities freely saleable among qualified institutional investors under special rules adopted by the SEC may be treated as liquid if they satisfy liquidity standards established by the Board. The continued liquidity of such securities is not as well assured as that of publicly traded securities, and accordingly the Board will monitor their liquidity. At June 30, 2019, the Fund held no restricted securities.

Securities Transactions and Investment Income.Securities transactions are accounted for on the trade datewith realized gain/(loss) on investments determined by using the identified cost method. Interest income (including amortization of premium and accretion of discount) is recorded on an accrual basis. Premiums and discounts on debt securities are amortized using the effective yield to maturity method. Dividend income is recorded on theex-dividend date, except for certain dividends from foreign securities that are recorded as soon after theex-dividend date as the Fund becomes aware of such dividends.

Determination of Net Asset Value and Calculation of Expenses.Certain administrative expenses are commonto, and allocated among, various affiliated funds. Such allocations are made on the basis of each fund’s average net assets or other criteria directly affecting the expenses as determined by the Adviser pursuant to procedures established by the Board.

In calculating the NAV per share of each class, investment income, realized and unrealized gains and losses, redemption fees, and expenses other than class specific expenses are allocated daily to each class of shares based upon the proportion of net assets of each class at the beginning of each day. Distribution expenses are borne solely by the class incurring the expense.

Distributions to Shareholders.Distributions to shareholders are recorded on theex-dividend date. Distributionsto shareholders are based on income and capital gains as determined in accordance with federal income tax regulations, which may differ from income and capital gains as determined under GAAP. These differences are primarily due to differing treatments of income and gains on various investment securities and foreign currency transactions held by the Fund, timing differences, and differing characterizations of distributions made by the Fund. Distributions from net investment income for federal income tax purposes include net realized gains on foreign currency transactions. These book/tax differences are either temporary or permanent in nature. Permanent differences were primarily due to utilization of tax equalization, prior year long term capital gain reversal on real estate investment trusts, and tax treatment of currency gains and losses. To the extent these differences are permanent, adjustments are made to the appropriate capital accounts in the period when the differences arise. These reclassifications have no impact on the NAV of the Fund.



The Gabelli Value 25 Fund Inc.

Notes to Financial Statements (Unaudited) (Continued)



The tax character of distributions paid during the year ended December 31, 2018 was as follows:


Distributions paid from:*


Ordinary income


Net long term capital gains





Total distributions paid







Total distributions paid differs from the Statement of Changes in Net Assets due to the utilization of equalization.

Provision for Income Taxes.The Fund intends to continue to qualify as a regulated investment companyunder Subchapter M of the Internal Revenue Code of 1986, as amended (the Code). It is the policy of the Fund to comply with the requirements of the Code applicable to regulated investment companies and to distribute substantially all of its net investment company taxable income and net capital gains. Therefore, no provision for federal income taxes is required.

The following summarizes the tax cost of investments and the related net unrealized appreciation at June 30, 2019:


     Cost     Gross
    Net Unrealized


    $152,228,680     $222,475,869    $(3,762,795)    $218,713,074

The Fund is required to evaluate tax positions taken or expected to be taken in the course of preparing the Fund’s tax returns to determine whether the tax positions are“more-likely-than-not” of being sustained by the applicable tax authority. Income tax and related interest and penalties would be recognized by the Fund as tax expense in the Statement of Operations if the tax positions were deemed not to meet themore-likely-than-not threshold. For the six months ended June 30, 2019, the Fund did not incur any income tax, interest, or penalties. As of June 30, 2019, the Adviser has reviewed all open tax years and concluded that there was no impact to the Fund’s net assets or results of operations. The Fund’s federal and state tax returns for the prior three fiscal years remain open, subject to examination. On an ongoing basis, the Adviser will monitor the Fund’s tax positions to determine if adjustments to this conclusion are necessary.

3. Investment Advisory Agreement and Other Transactions.The Fund has entered into an investmentadvisory agreement (the Advisory Agreement) with the Adviser which provides that the Fund will pay the Adviser a fee, computed daily and paid monthly, at the annual rate of 1.00% of the value of its average daily net assets. In accordance with the Advisory Agreement, the Adviser provides a continuous investment program for the Fund’s portfolio, oversees the administration of all aspects of the Fund’s business and affairs, and pays the compensation of all Officers and Directors of the Fund who are affiliated persons of the Adviser.

Effective October 1, 2016, the Adviser contractually agreed to waive its investment advisory fee and/or reimburse expenses of Class I Shares to the extent necessary to maintain the total operating expenses (excluding brokerage, acquired fund fees and expenses, interest, taxes, and extraordinary expenses) until at least April 30, 2020 at no more than 1.00% of the value of its average daily net assets. In addition, the Fund has agreed, during the three year period following any waiver or reimbursement by the Adviser, to repay such amount to the extent, that after giving the effect to the repayment, such adjusted annualized total operating expenses of the Fund would not exceed 1.00% of the value of the Fund’s average daily net assets for Class I. The agreement is renewable annually. At June 30, 2019, the cumulative amount which the Fund may repay the Adviser is $254,078.



The Gabelli Value 25 Fund Inc.

Notes to Financial Statements (Unaudited) (Continued)



For the year ended December 31, 2016, expiring December 31,  2019

 $ 11,790 

For the year ended December 31, 2017, expiring December 31, 2020


For the year ended December 31, 2018, expiring December 31, 2021


For the six months ended June 30, 2019, expiring December 31, 2022








The Fund pays each Director who is not considered an affiliated person an annual retainer of $9,000 plus $2,000 for each Board meeting attended, and they are reimbursed for any out of pocket expenses incurred in attending meetings. All Board committee members receive $500 per meeting attended. The Chairman of the Audit Committee and the Lead Director each receives an annual fee of $2,000 per year. The Chairman of the Nominating Committee receives an annual fee of $2,500. A Director may receive a single meeting fee, allocated among the participating funds, for attending certain meetings held on behalf of multiple funds. Directors who are directors or employees of the Adviser or an affiliated company receive no compensation or expense reimbursement from the Fund.

4.Distribution Plan.The Fund’s Board has adopted a distribution plan (the Plan) for each class of shares,except for Class I Shares, pursuant to Rule12b-1 under the 1940 Act. Under the Class AAA, Class A, and Class C Share Plans, payments are authorized to G.distributors, LLC (the Distributor), an affiliate of the Adviser, at annual rates of 0.25%, 0.25%, and 1.00%, respectively, of the average daily net assets of those classes, the annual limitations under each Plan. Such payments are accrued daily and paid monthly.

5.Portfolio Securities.Purchases and sales of securities during the six months ended June 30, 2019, otherthan short term securities and U.S. Government obligations, aggregated $8,066,246 and $33,914,193, respectively.

6.Transactions with Affiliates and Other Arrangements.During the six months ended June 30, 2019, theFund paid $8,183 in brokerage commissions on security trades to G.research, LLC, an affiliate of the Adviser. Additionally, the Distributor retained a total of $1,749 from investors representing commissions (sales charges and underwriting fees) on sales and redemptions of Fund shares.

During the six months ended June 30, 2019, the Fund received credits from a designated broker who agreed to pay certain Fund operating expenses. The amount of such expenses paid through this directed brokerage arrangement during this period was $2,026.

The cost of calculating the Fund’s NAV per share is a Fund expense pursuant to the Advisory Agreement. Under thesub-administration agreement with Bank of New York Mellon, the fees paid include the cost of calculating the Fund’s NAV. The Fund reimburses the Adviser for this service. During the six months ended June 30, 2019, the Fund accrued $22,500 in accounting fees in the Statement of Operations.

7. Capital Stock.The Fund offers four classes of shares – Class AAA Shares, Class A Shares, Class C Shares,and Class I Shares. Class AAA Shares and Class I Shares are offered without a sales charge. Class A Shares are subject to a maximumfront-end sales charge of 5.75%. Class C Shares are subject to a 1.00% contingent deferred sales charge for one year after purchase.

The Fund imposes a redemption fee of 2.00% on all classes of shares that are redeemed or exchanged on or before the seventh day after the date of a purchase. The redemption fee is deducted from the proceeds otherwise payable to the redeeming shareholders and is retained by the Fund as an increase inpaid-in capital.



The Gabelli Value 25 Fund Inc.

Notes to Financial Statements (Unaudited) (Continued)



The redemption fees retained by the Fund during the six months ended June 30, 2019 and the year ended December 31, 2018, if any, can be found in the Statement of Changes in Net Assets under Redemption Fees.

Transactions in shares of capital stock were as follows:


   Six Months Ended
June 30,  2019
      Year Ended
December 31, 2018
   Shares   Amount      Shares   Amount 

Class AAA


Shares sold

   28,712   $389,193     57,842   $834,317 

Shares issued upon reinvestment of distributions

            22,909    294,155 

Shares redeemed

   (44,761   (639,743    (83,070   (1,272,911













Net decrease

   (16,049  $(250,550    (2,319  $(144,439













Class A


Shares sold

   166,023   $2,456,466     141,733   $2,139,174 

Shares issued upon reinvestment of distributions

            1,868,662    24,086,847 

Shares redeemed

   (1,216,622   (17,604,890    (3,719,152   (56,592,005













Net decrease

   (1,050,599  $(15,148,424    (1,708,757  $(30,365,984













Class C


Shares sold

   2,237   $24,638     118,768   $1,287,635 

Shares issued upon reinvestment of distributions

            74,169    723,144 

Shares redeemed

   (220,792   (2,467,147    (215,892   (2,536,976













Net decrease

   (218,555  $(2,442,509    (22,955  $(526,197













Class I


Shares sold

   122,747   $1,781,115     415,344   $6,550,513 

Shares issued upon reinvestment of distributions

            340,330    4,376,640 

Shares redeemed

   (198,383   (2,878,698    (956,604   (14,871,623













Net decrease

   (75,636  $(1,097,583    (200,930  $(3,944,470













Class T*


Shares redeemed

      $     (67  $(1,118













Net decrease

            (67  $(1,118















Class T Shares were liquidated on September 21, 2018.


8.Indemnifications.The Fund enters into contracts that contain a variety of indemnifications. The Fund’smaximum exposure under these arrangements is unknown. However, the Fund has not had prior claims or losses pursuant to these contracts. Management has reviewed the Fund’s existing contracts and expects the risk of loss to be remote.

9.Subsequent Events.Management has evaluated the impact on the Fund of all subsequent events occurringthrough the date the financial statements were issued and has determined that there were no subsequent events requiring recognition or disclosure in the financial statements.



Gabelli/GAMCO Funds and Your Personal Privacy



Who are we?

The Gabelli/GAMCO Funds are investment companies registered with the Securities and Exchange Commission under the Investment Company Act of 1940. We are managed by Gabelli Funds, LLC, which is affiliated with GAMCO Investors, Inc., a publicly held company with subsidiaries and affiliates that provide investment advisory services for a variety of clients.

What kind ofnon-public information do we collect about you if you become a fund shareholder?

If you apply to open an account directly with us, you will be giving us somenon-public information about yourself. Thenon-public information we collect about you is:



Information you give us on your application form.This could include your name, address, telephonenumber, social security number, bank account number, and other information.




Information about your transactions with us, any transactions with our affiliates, and transactions with the entities we hire to provide services to you.This would include information about the shares thatyou buy or redeem. If we hire someone else to provide services — like a transfer agent — we will also have information about the transactions that you conduct through them.


What information do we disclose and to whom do we disclose it?

We do not disclose anynon-public personal information about our customers or former customers to anyone other than our affiliates, our service providers who need to know such information, and as otherwise permitted by law. If you want to find out what the law permits, you can read the privacy rules adopted by the Securities and Exchange Commission. They are in volume 17 of the Code of Federal Regulations, Part 248. The Commission often posts information about its regulations on its website,

What do we do to protect your personal information?

We restrict access tonon-public personal information about you to the people who need to know that information in order to provide services to you or the fund and to ensure that we are complying with the laws governing the securities business. We maintain physical, electronic, and procedural safeguards to keep your personal information confidential.


This page was intentionally left blank.


One Corporate Center

Rye, NY 10580-1422

Portfolio Management Team Biographies

Mario J. Gabelli, CFA,is Chairman, Chief Executive Officer, and Chief Investment Officer - Value Portfolios ofGAMCO Investors, Inc. that he founded in 1977, and Chief Investment Officer - Value Portfolios of Gabelli Funds, LLC and GAMCO Asset Management Inc. He is also Executive Chairman of Associated Capital Group, Inc. Mr. Gabelli is a summa cum laude graduate of Fordham University and holds an MBA degree from Columbia Business School and Honorary Doctorates from Fordham University and Roger Williams University.

Christopher J. Marangijoined Gabelli in 2003 as a research analyst. Currently he is a Managing Director andCo-Chief Investment Officer for GAMCO Investors, Inc.’s Value team. In addition, he serves as a portfolio manager of Gabelli Funds, LLC and manages several funds within the Gabelli/GAMCO Fund Complex. Mr. Marangi graduated magna cum laude and Phi Beta Kappa with a BA in Political Economy from Williams College and holds an MBA degree with honors from Columbia Business School.




We have separated the portfolio managers’ commentary from the financial statements and investment portfolio due to corporate governance regulations stipulated by the Sarbanes-Oxley Act of 2002. We have done this to ensure that the content of the portfolio managers’ commentary is unrestricted. Both the commentary and the financial statements, including the portfolio of investments, will be available on our website at



One Corporate Center

Rye, New York 10580-1422

t  800-GABELLI (800-422-3554)

f  914-921-5118



Net Asset Value per share available daily

by calling 800-GABELLI after 7:00 P.M.




Mario J. Gabelli, CFA

Chairman and Chief

Executive Officer,

GAMCO Investors, Inc.

Executive Chairman,

Associated Capital Group, Inc.


Anthony J. Colavita


Anthony J. Colavita, P.C.


Robert J. Morrissey


Morrissey, Hawkins & Lynch


Kuni Nakamura


Advanced Polymer, Inc.


Werner J. Roeder

Former Medical Director,

Lawrence Hospital




Bruce N. Alpert



John C. Ball



Agnes Mullady

Vice President


Andrea R. Mango



Richard J. Walz

Chief Compliance Officer



G.distributors, LLC



The Bank of New York






DST Asset Manager

Solutions, Inc.



Paul Hastings LLP



This report is submitted for the general information of the shareholders of The Gabelli Value 25 Fund Inc. It is not authorized for distribution to prospective investors unless preceded or accompanied by an effective prospectus.








Item 2.

Code of Ethics.

Not applicable.


Item 3.

Audit Committee Financial Expert.

Not applicable.


Item 4.

Principal Accountant Fees and Services.

Not applicable.


Item 5.

Audit Committee of Listed Registrants.

Not applicable.


Item 6.




Schedule of Investments in securities of unaffiliated issuers as of the close of the reporting period is included as part of the report to shareholders filed under Item 1 of this form.



Not applicable.


Item 7.

Disclosure of Proxy Voting Policies and Procedures forClosed-End Management Investment Companies.

Not applicable.


Item 8.

Portfolio Managers ofClosed-End Management Investment Companies.

Not applicable.

Item 9.

Purchases of Equity Securities byClosed-End Management Investment Company and Affiliated Purchasers.

Not applicable.


Item 10.

Submission of Matters to a Vote of Security Holders.

There have been no material changes to the procedures by which the shareholders may recommend nominees to the registrant’s Board of Directors, where those changes were implemented after the registrant last provided disclosure in response to the requirements of Item 407(c)(2)(iv) of RegulationS-K (17 CFR 229.407) (as required by Item 22(b)(15) of Schedule 14A (17 CFR240.14a-101)), or this Item.


Item 11.

Controls and Procedures.



The registrant’s principal executive and principal financial officers, or persons performing similar functions, have concluded that the registrant’s disclosure controls and procedures (as defined inRule 30a-3(c) under the Investment Company Act of 1940, as amended (the “1940 Act”) (17 CFR270.30a-3(c))) are effective, as of a date within 90 days of the filing date of the report that includes the disclosure required by this paragraph, based on their evaluation of these controls and procedures required by Rule30a-3(b) under the 1940 Act (17 CFR270.30a-3(b)) and Rules13a-15(b) or15d-15(b) under the Securities Exchange Act of 1934, as amended (17 CFR240.13a-15(b) or240.15d-15(b)).



There were no changes in the registrant’s internal control over financial reporting (as defined inRule 30a-3(d) under the 1940 Act (17 CFR270.30a-3(d))) that occurred during the period covered by this reportthat has materially affected, or is reasonably likely to materially affect, the registrant’s internal control over financial reporting.


Item 12.

Disclosure of Securities Lending Activities forClosed-End Management Investment Companies.

Not applicable.


Item 13.




Not applicable.



Certifications pursuant to Rule30a-2(a) under the 1940 Act and Section 302 of the Sarbanes-Oxley Act of 2002 are attached hereto.


Not applicable.



Not applicable.



Certifications pursuant to Rule30a-2(b) under the 1940 Act and Section 906 of the Sarbanes- Oxley Act of 2002 are attached hereto.



Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, the registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.




   The Gabelli Value 25 Fund Inc.

By (Signature and Title)*


      /s/ Bruce N. Alpert


      Bruce N. Alpert, Principal Executive Officer




Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, this report has been signed below by the following persons on behalf of the registrant and in the capacities and on the dates indicated.


By (Signature and Title)*


      /s/ Bruce N. Alpert


      Bruce N. Alpert, Principal Executive Officer




By (Signature and Title)*


      /s/ John C. Ball


      John C. Ball, Principal Financial Officer and Treasurer




* Print the name and title of each signing officer under his or her signature.