GABELLI UTILITY TRUST — Director's Dealing 2009

Jan 9, 2009

SEC Form 3 — Initial Statement of Beneficial Ownership

Issuer: GABELLI UTILITY TRUST (GUT)
CIK: 0001080720
Period of Report: 2008-12-31

Reporting Person: MERRILL LYNCH & CO., INC. (10% Owner)
Reporting Person: MERRILL LYNCH, PIERCE, FENNER & SMITH INC. (10% Owner)

Holdings (Non-Derivative)

Security	Shares	Ownership
Auction Rate Preferred	419	Indirect

Footnotes

F1: The securities reported on this Form 3 are subject to repurchase under the terms of Merrill Lynch & Co.'s ("MLCO") settlement
with the Securities and Exchange Commission (the "Commission"), et alia, with respect to certain auction rate securities
("Subject Securities") sold by MLCO and/or held by customers in accounts at MLCO. The repurchases of the Subject Securities
by MLCO, and the reporting of its holdings of such Subject Securities by MLCO, are being made in reliance on the Auction
Rate Securities-Global Relief Letter issued by the Commission on September 22, 2008 (the "Relief Letter"). In reliance on
the Relief Letter, we are reporting our holdings of each series of preferred stock of the issuer on a consolidated basis as
a single class of securities.

F2: In further reliance on the Relief Letter, we will not file Forms 4 to report changes in our beneficial ownership of the
issuer's preferred stock. However, in compliance with the terms of the Relief Letter, we hereby undertake to provide upon
request by the Commission, the issuer or a security holder of the issuer, complete information regarding the number of
equity securities of the issuer purchased or sold at each different price and date of all transactions in such securities
that occurred after we became a 10% owner but prior to the date of this filing.

F3: Merrill Lynch & Co., Inc. indirectly through its wholly-owned subsidiary Merrill Lynch, Pierce, Fenner & Smith Incorporated
owns 419 shares of the issuer's preferred stock.