DEAN WITTER PORTFOLIO STRATEGY FUND LP
10-Q, 1999-08-16
COMMODITY CONTRACTS BROKERS & DEALERS
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                         UNITED STATES
               SECURITIES AND EXCHANGE COMMISSION
                     Washington, D.C. 20549

                           FORM 10-Q


[X]   Quarterly  report pursuant to Section 13 or  15(d)  of  the
Securities Exchange Act of 1934
For the quarterly period ended June 30, 1999 or

[  ]   Transition report pursuant to Section 13 or 15(d)  of  the
Securities Exchange Act of 1934
For the transition period from               to

Commission File No. 0-19046

                  DEAN WITTER PORTFOLIO STRATEGY FUND L.P.
     (Exact name of registrant as specified in its charter)


                  Delaware                             13-3589337
(State or other jurisdiction of              (I.R.S. Employer
incorporation  or organization)                    Identification
No.)


c/o Demeter Management Corporation
Two  World Trade Center, 62 Fl., New York,  NY              10048
(Address of principal executive offices)               (Zip Code)

Registrant's telephone number, including area code (212) 392-5454



(Former  name, former address, and former fiscal year, if changed
since last report)

Indicate  by check-mark whether the registrant (1) has filed  all
reports  required  to be filed by Section  13  or  15(d)  of  the
Securities  Exchange Act of 1934 during the preceding  12  months
(or  for such shorter period that the registrant was required  to
file  such  reports),  and (2) has been subject  to  such  filing
requirements for the past 90 days.

Yes    X            No











<PAGE>
<TABLE>

            DEAN WITTER PORTFOLIO STRATEGY FUND L.P.

             INDEX TO QUARTERLY REPORT ON FORM 10-Q

                         June 30, 1999

<CAPTION>

PART I. FINANCIAL INFORMATION
<S>                                                        <C>
Item 1.  Financial Statements

     Statements of Financial Condition
     June 30, 1999 (Unaudited) and December 31, 1998.........2

     Statements of Operations for the Quarters Ended
     June 30, 1999 and 1998 (Unaudited)......................3

     Statements of Operations for the Six Months Ended
     June 30, 1999 and 1998 (Unaudited)......................4

     Statements of Changes in Partners' Capital for the
     Six Months Ended June 30, 1999 and 1998
     (Unaudited).............................................5

     Statements of Cash Flows for the Six Months Ended
     June 30, 1999 and 1998 (Unaudited)......................6

     Notes to Financial Statements (Unaudited) ...........7-11

Item 2. Management's Discussion and Analysis
        of Financial Condition and Results of
        Operations.......................................12-21

Item 3. Quantitative and Qualitative Disclosures
        about Market Risk ...............................21-33

PART II. OTHER INFORMATION

Item 1. Legal Proceedings...................................34

Item    6.        Exhibits    and    Reports    on    Form     8-
K....................34




</TABLE>







<PAGE>
<TABLE>


                 PART I.  FINANCIAL INFORMATION

Item 1.  Financial Statements

            DEAN WITTER PORTFOLIO STRATEGY FUND L.P.
               STATEMENTS OF FINANCIAL CONDITION
<CAPTION>
                                      June 30,     December 31,
                                        1999           1998
                                         $              $
                                    (Unaudited)


ASSETS
<S>                                     <C>            <C>
Equity in futures interests trading accounts:
 Cash                            124,621,565     119,724,918
 Net unrealized gain on open contracts    11,327,988                   12,941,546

      Total Trading Equity       135,949,553     132,666,464

Interest receivable (DWR)            378,559         366,700

                                  Total Assets  136,328,112        133,033,164


LIABILITIES AND PARTNERS' CAPITAL

Liabilities

 Incentive fees payable            1,541,384          305,087
 Redemptions payable               1,199,470       1,065,454
 Management fees payable             454,076         443,168
 Accrued administrative expenses          112,390          85,003

      Total Liabilities            3,307,320       1,898,712

Partners' Capital

 Limited Partners (47,296.130 and
       49,902.250 Units, respectively)131,420,279  129,638,096
 General Partner (576 Units)       1,600,513       1,496,356

 Total Partners' Capital         133,020,792     131,134,452

  Total  Liabilities and Partners' Capital    136,328,112     133
,033,164


NET ASSET VALUE PER UNIT            2,778.67         2,597.84
<FN>
          The accompanying notes are an integral part
                 of these financial statements.
</TABLE>
<PAGE>
<TABLE>
            DEAN WITTER PORTFOLIO STRATEGY FUND L.P.
                     STATEMENTS OF OPERATIONS
                           (Unaudited)


<CAPTION>
                                 For the Quarters Ended June 30,

                                       1999           1998
                                        $            $
REVENUES
<S>                           <C>            <C>
 Trading profit (loss):
    Realized                       6,993,609  5,564,067
    Net change in unrealized       6,084,623   (8,394,261)

      Total Trading Results       13,078,232  (2,830,194)

 Interest Income (DWR)             1,125,512    1,283,889
      Total Revenues              14,203,744   (1,546,305)

EXPENSES

 Incentive fees                    1,548,449      -
 Brokerage commissions (DWR)       1,351,067  1,520,055
 Management fees                   1,326,417  1,248,472
 Transaction fees and costs          91,363      99,652
 Administrative expenses             26,000          24,000

      Total Expenses               4,343,296     2,892,179


NET INCOME (LOSS)                  9,860,448   (4,438,484)


NET INCOME (LOSS) ALLOCATION

 Limited Partners                  9,743,517  (4,361,087)
 General Partner                     116,931     (77,397)

NET INCOME (LOSS) PER UNIT

 Limited Partners                     203.01      (80.96)
 General Partner                     203.01      (80.96)
<FN>



          The accompanying notes are an integral part
                 of these financial statements.

</TABLE>

<PAGE>
<TABLE>
            DEAN WITTER PORTFOLIO STRATEGY FUND L.P.
                     STATEMENTS OF OPERATIONS
                           (Unaudited)


<CAPTION>
                                For the Six Months Ended June 30,

                                       1999            1998
                                        $            $
REVENUES
<S>                        <C>               <C>
 Trading profit (loss):
    Realized                    15,412,575   10,362,591
    Net change in unrealized     (1,613,558)    (13,044,665)

      Total Trading Results     13,799,017    (2,682,074)

 Interest Income (DWR)           2,206,529        2,639,442
      Total Revenues            16,005,546           (42,632)


EXPENSES

 Brokerage commissions (DWR)     2,859,406    2,861,922
 Management fees                 2,614,600    2,568,352
 Incentive fees                  1,548,449               -
 Transaction fees and costs        202,256      205,860
 Administrative expenses            52,000        51,000

                                                Total    Expenses
7,276,711                                        5,687,134


NET INCOME (LOSS)                8,728,835      (5,729,766)


NET INCOME (LOSS) ALLOCATION

 Limited Partners                8,624,678    (5,630,374)
 General Partner                   104,157      (99,392)

NET INCOME (LOSS) PER UNIT

 Limited Partners                   180.83       (103.97)
 General Partner                    180.83      (103.97)
<FN>



          The accompanying notes are an integral part
                 of these financial statements.
</TABLE>

<PAGE>
<TABLE>
            DEAN WITTER PORTFOLIO STRATEGY FUND L.P.
           STATEMENTS OF CHANGES IN PARTNERS' CAPITAL
        For the Six Months Ended June 30, 1999 and 1998
                          (Unaudited)

<CAPTION>



                          Units of
                        Partnership Limited   General
                          Interest   Partners Partner    Total


<S>           <C>                          <C>                        <C>
<C>
Partners' Capital,
 December 31, 1997   56,305.245            $131,363,711          $2,268,933
$133,632,644

Net Loss               -                   (5,630,374)           (99,392)
(5,729,766)

Redemptions           (2,747.340)           (6,358,855)                  -
(6,358,855)

Partners' Capital,
 June 30, 1998       53,557.905            $119,374,482          $2,169,541
$121,544,023




Partners' Capital,
 December 31, 1998   50,478.250            $129,638,096          $1,496,356
$131,134,452

Net Income               -                 8,624,678             104,157
8,728,835

Redemptions           (2,606.120)              (6,842,495)                -
(6,842,495)

Partners' Capital,
 June 30, 1999         47,872.130          $131,420,279          $1,600,513
$133,020,792





<FN>



           The accompanying notes are an integral part
                 of these financial statements.


</TABLE>




<PAGE>
<TABLE>
            DEAN WITTER PORTFOLIO STRATEGY FUND L.P.
                    STATEMENTS OF CASH FLOWS
                           (Unaudited)


<CAPTION>



                                For the Six Months Ended June 30,

                                       1999            1998
                                        $            $
CASH FLOWS FROM OPERATING ACTIVITIES
<S>                           <C>                        <C>
Net   income   (loss)                    8,728,835              (
5,729,766)
Noncash item included in net income (loss):
      Net  change  in  unrealized        1,613,558              1
3,044,665

(Increase) decrease in operating assets:
    Interest receivable (DWR)        (11,859)            54,211
      Due  from  DWR                        -                   (
128,271)

Increase (decrease) in operating liabilities:
          Incentive      fees      payable              1,236,297
(801,115)
          Management      fees      payable                10,908
(41,857)
         Accrued     administrative     expenses           27,387
35,057

   Net   cash   provided  by  operating  activities    11,605,126
6,432,924

CASH FLOWS FROM FINANCING ACTIVITIES

 Increase in redemptions payable    134,016              374,362
      Redemptions      of      units                  (6,842,495)
(6,358,855)

Net    cash    used   for   financing   activities    (6,708,479)
(5,984,493)


Net increase in cash              4,896,647              448,431

Balance      at     beginning     of     period       119,724,918
125,280,410

Balance      at      end     of     period            124,621,565
125,728,841

<FN>

          The accompanying notes are an integral part
                 of these financial statements.

</TABLE>





<PAGE>

            DEAN WITTER PORTFOLIO STRATEGY FUND L.P.

                  NOTES TO FINANCIAL STATEMENTS

                           (UNAUDITED)



The  financial statements include, in the opinion of  management,

all  adjustments necessary for a fair presentation of the results

of  operations  and financial condition of Dean Witter  Portfolio

Strategy Fund L.P. (the "Partnership").  The financial statements

and condensed notes herein should be read in conjunction with the

Partnership's December 31, 1998 Annual Report on Form 10-K.

1.  Organization

Dean Witter Portfolio Strategy Fund L.P. is a limited partnership

organized  to  engage  primarily in the  speculative  trading  of

futures  and forward contracts on physical commodities and  other

commodity  interests  (collectively, "futures  interests").   The

general   partner  for  the  Partnership  is  Demeter  Management

Corporation  ("Demeter").  The non-clearing commodity  broker  is

Dean  Witter  Reynolds Inc. ("DWR") and an unaffiliated  clearing

commodity  broker, Carr Futures Inc. ("Carr"), provides  clearing

and  execution  services.  Both Demeter and DWR are  wholly-owned

subsidiaries of Morgan Stanley Dean Witter & Co. ("MSDW").   John

W.  Henry & Company, Inc. (the "Trading Advisor") is the  trading

advisor to the Partnership.







<PAGE>

            DEAN WITTER PORTFOLIO STRATEGY FUND L.P.
            NOTES TO FINANCIAL STATEMENTS (CONTINUED)



2.  Related Party Transactions

The Partnership's cash is on deposit with DWR and Carr in futures

interests trading accounts to meet margin requirements as needed.

DWR  pays interest on these funds based on a prevailing  rate  on

U.S.   Treasury  bills.  Brokerage  expenses  incurred   by   the

Partnership are paid to DWR.



3.  Financial Instruments

The Partnership trades primarily futures and forward contracts on

physical commodities and other commodity interests.  Futures  and

forwards   represent  contracts  for  delayed  delivery   of   an

instrument  at  a  specified date and price.   Risk  arises  from

changes  in  the  value  of  these contracts  and  the  potential

inability  of  counterparties to perform under the terms  of  the

contracts.   There  are numerous factors which may  significantly

influence the market value of these contracts, including interest

rate volatility.



In  June  1998, the Financial Accounting Standards  Board  issued

Statement  of  Financial Accounting Standard  ("SFAS")  No.  133,

"Accounting  for  Derivative Instruments and Hedging  Activities"

effective  for fiscal years beginning after June 15,  1999.   The

Partnership  elected  to adopt the provisions  of  SFAS  No.  133

beginning  with  the  fiscal year that ended December  31,  1998.

SFAS  No. 133 supersedes SFAS No. 119 and No. 105, which required

the



<PAGE>
            DEAN WITTER PORTFOLIO STRATEGY FUND L.P.
            NOTES TO FINANCIAL STATEMENTS (CONTINUED)



disclosure of average aggregate fair values and contract/notional

values, respectively, of derivative financial instruments for  an

entity  which carries its assets at fair value.  The  application

of  SFAS  No.  133  does  not have a significant  effect  on  the

Partnership's financial statements.



The  net  unrealized  gain on open contracts  is  reported  as  a

component  of  "Equity in futures interests trading accounts"  on

the Statements of Financial Condition and totaled $11,327,988 and

$12,941,546 at June 30, 1999 and December 31, 1998, respectively.

Of  the $11,327,988 net unrealized gain on open contracts at June

30,   1999,   $11,122,347  related  to  exchange-traded   futures

contracts  and  $205,641  related to off-exchange-traded  forward

currency contracts.



Of  the  $12,941,546  net unrealized gain on  open  contracts  at

December 31, 1998, $13,874,856 related to exchange-traded futures

contracts  and $(933,310) related to off-exchange-traded  forward

currency contracts.



Exchange-traded futures contracts held by the Partnership at June

30,  1999  and  December 31, 1998 mature through  June  2000  and

December 1999, respectively. Off-exchange-traded forward currency

contracts held by the Partnership at June 30, 1999 and December

<PAGE>

            DEAN WITTER PORTFOLIO STRATEGY FUND L.P.
            NOTES TO FINANCIAL STATEMENTS (CONTINUED)


31,   1998   mature  through  September  1999  and  March   1999,

respectively.



The  Partnership  is subject to the credit risk  associated  with

counterparty  non-performance.  The credit risk  associated  with

the  instruments in which the Partnership is involved is  limited

to  the  amounts  reflected  in the Partnership's  Statements  of

Financial  Condition.  DWR and Carr act as the futures commission

merchants  or  the counterparties with respect  to  most  of  the

Partnership's  assets.  Exchange-traded  futures  contracts   are

marked  to  market  on  a daily basis, with variations  in  value

settled  on  a  daily basis. Each of DWR and Carr, as  a  futures

commission  merchant for all of the Partnership's exchange-traded

futures contracts, are required, pursuant to regulations  of  the

Commodity  Futures Trading Commission ("CFTC") to segregate  from

their  own  assets, and for the sole benefit of  their  commodity

customers, all funds held by them with respect to exchange-traded

futures   contracts,  including  an  amount  equal  to  the   net

unrealized  gain on all open futures contracts, which  funds,  in

the  aggregate, totaled $135,743,912 and $133,599,774 at June 30,

1999 and December 31, 1998, respectively.


With  respect  to  the Partnership's off-exchange-traded  forward

currency  contracts, there are no daily settlements of variations

in value nor is there any requirement that an amount equal to the

net  unrealized  gain  on open forward contracts  be  segregated.

With   respect  to  those  off-exchange-traded  forward  currency

contracts,

<PAGE>

            DEAN WITTER PORTFOLIO STRATEGY FUND L.P.
            NOTES TO FINANCIAL STATEMENTS (CONCLUDED)


the  Partnership  is at risk to the ability  of  Carr,  the  sole

counterparty  on  all  of  such contracts,  to  perform.   Carr's

parent,   Credit  Agricole  Indosuez,  has  guaranteed   to   the

Partnership  payment  of  the  net  liquidating  value   of   the

transactions  in  the Partnership's account with Carr  (including

foreign currency contracts).








































<PAGE>

Item   2.  MANAGEMENT'S  DISCUSSION  AND  ANALYSIS  OF  FINANCIAL
CONDITION AND RESULTS OF OPERATIONS

Liquidity -  Assets of the Partnership are deposited with DWR  as

non-clearing  broker  and  Carr as clearing  broker  in  separate

futures interest trading accounts. Such assets are held in either

non-interest bearing bank accounts or in securities  approved  by

the  CFTC  for  investment of customer funds.  The  Partnership's

assets held by DWR and Carr may be used as margin solely for  the

Partnership's trading.  Since the Partnership's sole  purpose  is

to   trade  in  futures  interests,  it  is  expected  that   the

Partnership  will continue to own such liquid assets  for  margin

purposes.



The  Partnership's investment in futures interests may, from time

to time, be illiquid.  Most United States futures exchanges limit

fluctuations in certain futures interest prices during  a  single

day  by  regulations  referred to as  "daily  price  fluctuations

limits" or "daily limits".  Pursuant to such regulations,  during

a  single trading day no trades may be executed at prices  beyond

the  daily limit.  If the price for a particular futures interest

has increased or decreased by an amount equal to the daily limit,

positions  in  such  futures interest can neither  be  taken  nor

liquidated  unless  traders are willing to effect  trades  at  or

within  the  limit.   Futures interests prices have  occasionally

moved the daily limit for several consecutive days with little or

no trading.  Such market conditions could prevent the Partnership

from  promptly  liquidating its futures interests and  result  in

restrictions on redemptions.



<PAGE>

There  is  no limitation on daily price moves in trading  forward

contracts  on  foreign  currency.  The  markets  for  some  world

currencies  have low trading volume and are illiquid,  which  may

prevent  the  Partnership from trading in potentially  profitable

markets  or  from  promptly  liquidating  unfavorable  positions,

subjecting  it  to substantial losses.  Either  of  these  market

conditions could result in restrictions on redemptions.


Capital  Resources - The Partnership does not have, nor  does  it

expect to have, any capital assets.  Future redemptions of  Units

of  Limited  Partnership  Interest ("Unit(s)")  will  affect  the

amount of funds available for investment in futures interests  in

subsequent periods.  Since they are at the discretion of  Limited

Partners,  it  is  not  possible  to  estimate  the  amount   and

therefore, the impact of future redemptions.



Results of Operations

For the Quarter and Six Months Ended June 30, 1999

For  the  quarter  ended June 30, 1999, the Partnership  recorded

total  trading revenues including interest income of  $14,203,744

and  posted  an  increase in Net Asset Value per Unit.  The  most

significant  gains were experienced in the global  interest  rate

futures  markets  from  long  Japanese  government  bond  futures

positions  as  prices rallied during April after  the  government

proposed  no new economic spending plan.  Investors continued  to

chose  higher yielding long-term debt instruments as  opposed  to

short-term  Japanese interest rate investments  during  May  thus

resulting in additional profits.  Short positions in U.S. bond

<PAGE>

futures were also profitable during May as domestic interest rate

prices dropped sharply due to a rise in the Consumer Price  Index

and  Alan Greenspan's comments regarding the unlikely possibility

of   continued   U.S.  economic  expansion  without   significant

inflation.   Additional  gains  were  recorded  in  the  currency

markets  from  short positions in the euro and  the  Swiss  franc

during  April and June as the value of these European  currencies

weakened  steadily  versus the U.S. dollar due  to  the  lack  of

economic  growth in the European community, the ongoing  military

conflict in Kosovo and strong economic data out of the  U.S.   In

the energy markets, gains were recorded early in the quarter from

long  crude oil futures positions as oil prices rallied to  their

highest  levels  since December 1997 due to  declining  inventory

levels  and  growing confidence that oil-exporting countries  are

cutting  production.  Oil prices jumped higher again in  June  on

unexpected  declines in U.S. stockpiles and on news  of  refinery

outages.   Smaller  gains were experienced in  the  global  stock

index futures markets from long Nikkei Index futures positions as

the  Japanese benchmark index reached its highest level  in  more

that  a year and a half during June encouraged by recent economic

growth  data  in  Japan.  These gains were  partially  offset  by

losses  in the soft commodities markets from long coffee  futures

positions as prices declined amid late May forecasts for a  cool-

pressure  system  in the major coffee producing  regions,  June's

warm  weather in Brazil and ample warehouse supplies.  Additional

losses  were  incurred  in the metal markets  from  short  silver

futures  positions  as silver prices were boosted  higher  during

April by perceptions of tightening supply levels and technically-

<PAGE>

driven buying. Total expenses for the three months ended June 30,

1999 were $4,343,296, resulting in net income of $9,860,448.  The

value  of  a Unit increased from $2,575.66 at March 31,  1999  to

$2,778.67 at June 30, 1999.



For  the six months ended June 30, 1999, the Partnership recorded

total  trading revenues including interest income of  $16,005,546

and  posted  an  increase in Net Asset Value per Unit.  The  most

significant  gains  were recorded in the  currency  markets  from

short  euro  and  Swiss  franc positions.   The  value  of  these

European  currencies weakened versus the U.S.  dollar  throughout

the  first  six months of the year on the strength  of  the  U.S.

economy, concerns pertaining to the economic health of Europe and

Japan  and  growing  uncertainty about  the  military  action  in

Yugoslavia.  Additional gains were recorded in the energy markets

from  long  crude  oil  futures positions  as  oil  prices  moved

significantly higher during March on news that both OPEC and non-

OPEC  countries  had agreed to cut total output  beginning  April

1st.   Oil prices continued to climb during April on declines  in

inventory  levels and growing confidence in production  cutbacks.

Smaller  gains  were recorded in the global stock  index  futures

positions  from long Nikkei Index futures positions  as  Japanese

equity  prices  experienced a strong upward move during  June  on

news that Japan's gross domestic product had grown much more than

market  expectations  and  on benign U.S.  Consumer  Price  Index

figures.  In the global interest rate futures markets, gains were

recorded  from  long Japanese bond futures positions  during  the

second quarter as prices moved higher due to no new economic

<PAGE>

spending plan.  A portion of these gains was offset by losses  in

the  metals markets from long silver futures positions as  prices

declined  during  mid-March  after  Berkshire  Hathaway's  annual

report  failed  to provide any new information on  the  company's

silver  positions.   Short silver futures positions  held  during

April  were  also  unfavorable as prices were boosted  higher  by

perceptions  of  tightening supply levels and  technically-driven

buying.   Additional losses were recorded in the soft commodities

markets  from  short coffee futures positions  as  prices  surged

during  late March as options-related buying triggered  waves  of

buy-stops at several key resistance levels, attracting fund short-

covering  and  again  during May due to cold weather  in  Brazil.

Total  expenses  for  the six months ended  June  30,  1999  were

$7,276,711, resulting in net income of $8,728,835.  The value  of

a Unit increased from $2,597.84 at December 31, 1998 to $2,778.67

at June 30, 1999.



For the Quarter and Six Months Ended June 30, 1998

For  the  quarter  ended June 30, 1998, the Partnership  recorded

total  trading  losses net of interest income of  $1,546,305  and

posted  a  decrease  in  Net  Asset Value  per  Unit.   The  most

significant  losses  were recorded in the financial  futures  and

currency  markets.  Losses were recorded from  long  global  bond

futures  positions  as  European  and  Australian  interest  rate

futures  prices reversed lower in April. Additional  losses  were

experienced   in  June  from  long  positions  in  Japanese   and

Australian bond futures as prices in these markets suddenly moved

lower in response to the coordinated intervention by the U.S. and

<PAGE>

Japanese  governments to halt the downward slide of the  Japanese

yen.   Long  S&P 500 Index futures positions experienced  smaller

losses   during  June.   Transactions  in  the  currency  markets

resulted  in losses for the quarter despite strong gains produced

in  May from short Japanese yen positions as the value of the yen

fell  to a seven and a half year low relative to the U.S. dollar.

Losses  were  recorded from long British pound positions  as  the

value  of the pound weakened relative to the U.S. dollar in  May.

Short  British pound positions held in June also produced  losses

as its value increased sharply relative to the U.S. dollar during

the  third  week  of  the month.  Smaller  currency  losses  were

recorded from short Swiss franc and German mark positions as  the

value of these currencies increased versus the U.S. dollar during

the  first half of the quarter.  Losses were also recorded in the

metals markets from trading gold futures during May and June.   A

portion  of  the  Partnership's overall  losses  for  the  second

quarter was offset by gains in the energy markets as short  crude

oil  futures positions profited as prices moved lower in May  and

June.   Additional  gains were recorded in the  soft  commodities

markets from short coffee futures positions as coffee prices also

declined for a majority of the quarter.  Total expenses  for  the

three months ended June 30, 1998 were $2,892,179, resulting in  a

net  loss  of  $4,438,484. The value of  a  Unit  decreased  from

$2,350.35 at March 31, 1998 to $2,269.39 at June 30, 1998.



For  the six months ended June 30, 1998, the Partnership recorded

total trading losses net of interest income of $42,632 and posted

a decrease in Net Asset Value per Unit.  The most significant

<PAGE>

trading  losses were recorded in the currency and metals markets.

Long British pound positions resulted in losses during May as the

value  of  the  pound  decreased versus the U.S.  dollar.   Short

British pound positions held during June also resulted in  losses

as  the  value  of  the  pound reversed  higher  during  mid-June

relative  to  the  U.S. dollar.  Similarly, gold futures  trading

during May and mid-June added to losses incurred during the first

quarter as a result of choppy price movement.  These losses  more

than  offset the gains from short Japanese yen positions  as  the

value  of the yen fell to a seven and a half year low versus  the

U.S.  dollar  during May.  Additional losses were experienced  in

the financial futures markets from trading U.S. Treasury bond and

Australian  bond  futures, as well as Nikkei  Index  futures,  as

prices  in these markets experienced short-term volatility during

a  majority  of  the first half of the year.  Profits  from  long

German bond futures positions during the first six months of  the

year  were  able to mitigate these losses.  Smaller  losses  were

recorded  in  the  agricultural markets  from  trading  corn  and

soybean  oil  futures.   A portion of the  Partnership's  overall

losses  during the first half of the year was offset by gains  in

the  energy markets from short crude oil futures positions as oil

prices  moved  downward  for a majority  of  the  first  quarter.

Following  a spike higher in late March, oil prices proceeded  to

move  lower  during  most of the second  quarter.   In  the  soft

commodities   markets,  trading  in  cotton  and  cocoa   futures

contributed additional gains.  Total expenses for the six  months

ended June 30, 1998 were $5,687,134, resulting in a net loss of



<PAGE>

$5,729,766.   The  value of a Unit decreased  from  $2,373.36  at

December 31, 1997 to $2,269.39 at June 30, 1998.



Year  2000 Problem.  Commodity pools, like financial and business

organizations  and individuals around the world,  depend  on  the

smooth functioning of computer systems.  Many computer systems in

use  today cannot recognize the computer code for the year  2000,

but revert to 1900 or some other date.  This is commonly known as

the  "Year  2000  Problem". The Partnership  could  be  adversely

affected  if computer systems used by it or any third party  with

whom  it has a material relationship do not properly process  and

calculate date-related information and data concerning  dates  on

or  after January 1, 2000.  Such a failure could adversely affect

the  handling or determination of futures trades and  prices  and

other services.



MSDW  began its planning for the Year 2000 Problem in  1995,  and

currently  has several hundred employees working on  the  matter.

It  has developed its own Year 2000 compliance plan to deal  with

the  problem and had the plan approved by the company's executive

management,   Board  of  Directors  and  Information   Technology

Department. Demeter is coordinating with MSDW to address the Year

2000  Problem  with  respect to Demeter's computer  systems  that

affect  the  Partnership.  This includes  hardware  and  software

upgrades, systems consulting and computer maintenance.





<PAGE>

Beyond  the  challenge  facing  internal  computer  systems,  the

systems  failure  of  any  of the third  parties  with  whom  the

Partnership  has a material relationship - the futures  exchanges

and  clearing organizations through which it trades, Carr, or the

Trading  Advisor - could result in a material financial  risk  to

the  Partnership.  All  U.S. futures  exchanges  are  subject  to

monitoring  by the CFTC of their Year 2000 preparedness  and  the

major  foreign futures exchanges are also expected to be  subject

to market-wide testing of their Year 2000 compliance during 1999.

Demeter  intends to monitor the progress of Carr and the  Trading

Advisor throughout 1999 in their Year 2000 compliance and,  where

applicable,  to  test its external interface with  Carr  and  the

Trading Advisor.



A  worst case scenario would be one in which trading of contracts

on  behalf  of the Partnership becomes impossible as a result  of

the  Year 2000 problem encountered by any third parties.  A  less

catastrophic  but  more likely scenario would  be  one  in  which

trading  opportunities diminish as a result of technical problems

resulting  in  illiquidity  and  fewer  opportunities   to   make

profitable trades. MSDW has begun developing various "contingency

plans" in the event that the systems of such third parties  fail.

Demeter  intends  to  consult closely with MSDW  in  implementing

those  plans.  Despite the best efforts of both Demeter and MSDW,

however,  it is possible that these steps will not be  sufficient

to avoid any adverse impact to the Partnership.




<PAGE>

Risks  Associated  With  the Euro.  On January  1,  1999,  eleven

countries  in  the  European Union established  fixed  conversion

rates on their existing sovereign currencies and converted  to  a

common   single  currency  (the  "euro").   During  a  three-year

transition  period,  the sovereign currencies  will  continue  to

exist  but  only as a fixed denomination of the euro.  Conversion

to  the euro prevents the Trading Advisor from trading in certain

currencies  and thereby limits its ability to take  advantage  of

potential market opportunities that might otherwise have  existed

had  separate  currencies been available  to  trade.  This  could

adversely affect the performance results of the Partnership.


Item  3.  QUANTITATIVE AND QUALITATIVE DISCLOSURES  ABOUT  MARKET
RISK

Introduction

The  Partnership  is a commodity pool engaged  primarily  in  the

speculative  trading of futures interests.  The market  sensitive

instruments  held  by  the Partnership are  acquired  solely  for

speculative   trading  purposes  and,  as  a   result,   all   or

substantially all of the Partnership's assets are subject to  the

risk  of trading loss.  Unlike an operating company, the risk  of

market sensitive instruments is integral, not incidental, to  the

Partnership's primary business activities.



The  futures interests traded by the Partnership involve  varying

degrees  of  related  market risk.  Such  market  risk  is  often

dependent  upon  changes in the level or volatility  of  interest

rates, exchange rates, and/or market values of financial

<PAGE>

instruments and commodities.  Fluctuations in related market risk

based  upon the aforementioned factors result in frequent changes

in  the  fair  value  of the Partnership's open  positions,  and,

consequently, in its earnings and cash flow.



The  Partnership's  total market risk is  influenced  by  a  wide

variety  of factors, including the diversification effects  among

the Partnership's existing open positions, the volatility present

within  the  market(s), and the liquidity of the  market(s).   At

varying  times,  each of these factors may act to  exacerbate  or

mute the market risk associated with the Partnership.



The  Partnership's past performance is not necessarily indicative

of   its   future  results.   Any  attempt  at  quantifying   the

Partnership's  market  risk  must be qualified  by  the  inherent

uncertainty  of its speculative trading, which may  cause  future

losses and volatility (i.e. "risk of ruin") far in excess of  the

Partnership's   experience   to  date   and/or   any   reasonable

expectation premised upon historical changes in the fair value of

its market sensitive instruments.



Quantifying the Partnership's Trading Value at Risk

The  following  quantitative disclosures regarding  the  Partner-

ship's market risk exposures contain "forward-looking statements"

within  the  meaning  of  the safe harbor  from  civil  liability

provided for such statements by the Private Securities Litigation

Reform Act of 1995 (set forth in Section 27A of the Securities

<PAGE>

Act  of  1933 and Section 21E of the Securities Exchange  Act  of

1934).   All quantitative disclosures in this section are  deemed

to be forward-looking statements for purposes of the safe harbor,

except for statements of historical fact.



The Partnership accounts for open positions on the basis of mark-

to-market accounting principles.  As such, any loss in the fair

value  of  the Partnership's open positions is directly reflected

in  the  Partnership's earnings, whether realized or  unrealized,

and  the  Partnership's cash flow, as profits and losses on  open

positions of exchange-traded futures interests are settled  daily

through variation margin.



The  Partnership's  risk exposure in the various  market  sectors

traded  by  the Trading Advisor is estimated below  in  terms  of

Value  at Risk ("VaR"). The VaR model employed by the Partnership

incorporates numerous variables that could impact the fair  value

of   the   Partnership's  trading  portfolio.   The   Partnership

estimates VaR using a model based on historical simulation with a

confidence   level   of  99%.   Historical  simulation   involves

constructing  a  distribution of hypothetical  daily  changes  in

trading  portfolio  value.  The VaR model  generally  takes  into

account linear exposures to price and interest rate risk.  Market

risks  that are incorporated in the VaR model include equity  and

commodity prices, interest rates, foreign exchange rates, as well

as   correlation   that  exists  among  these   variables.    The

hypothetical  changes  in  portfolio value  are  based  on  daily

observed percentage changes in key market indices or other market

factors ("market risk factors")

<PAGE>

to  which  the  portfolio  is sensitive.   In  the  case  of  the

Partnership's   VaR,   the  historical  observation   period   is

approximately  four  years.  The Partnership's  one-day  99%  VaR

corresponds to the negative change in portfolio value that, based

on  observed  market risk factor moves, would have been  exceeded

once in 100 trading days.



VaR models such as the Partnership's are continually evolving  as

trading  portfolios  become more diverse and modeling  techniques

and systems capabilities improve.  It must also be noted that the

VaR  model is used to quantify market risk for historic reporting

purposes  only  and  is  not utilized by either  Demeter  or  the

Trading Advisor in their daily risk management activities.



The Partnership's Value at Risk in Different Market Sectors

The  following  table  indicates  the  VaR  associated  with  the

Partnership's open positions as a percentage of total Net  Assets

by market category as of June 30, 1999.  As of June 30, 1999, the

Partnership's   total  capitalization  was   approximately   $133

million.

     Primary Market             June 30, 1999
     Risk Category              Value at Risk

     Interest Rate                  (1.75)%

     Currency                       (2.43)

     Equity                         (0.33)

      Commodity                          (0.69)

      Aggregate Value at Risk       (2.73)%





<PAGE>

Aggregate  value  at  risk represents the aggregate  VaR  of  the

Partnership's open positions and not the sum of the  VaR  of  the

individual categories listed above.  Aggregate VaR will be  lower

as  it  takes into account correlation among different  positions

and categories.



The  table  above  represents the VaR of the  Partnership's  open

positions   at  June  30,  1999  only  and  is  not   necessarily

representative  of  either the historic  or  future  risk  of  an

investment  in  the  Partnership.   As  the  Partnership's   sole

business   is  the  speculative  trading  of  primarily   futures

interests, the composition of its portfolio of open positions can

change significantly over any given time period or even within  a

single  trading  day.   Such  changes  in  open  positions  could

materially   impact  market  risk  as  measured  by  VaR   either

positively or negatively.



The table below supplements the quarter-end VaR by presenting the

Partnership's high, low and average VaR as a percentage of  total

Net Assets for the four quarterly reporting periods from July  1,

1998 through June 30, 1999.

Primary Market Risk Category        High      Low      Average

Interest Rate                      (2.24)%   (1.50)%    (1.86)%

Currency                           (2.88)    (1.16)     (2.08)

Equity                             (0.57)    (0.33)     (0.40)

Commodity                          (0.69)    (0.60)     (0.63)

Aggregate Value at Risk            (3.42)%   (2.27)%    (2.77)%

<PAGE>

Limitations on Value at Risk as an Assessment of Market Risk

The  face  value  of the market sector instruments  held  by  the

Partnership is typically many times the applicable margin require-

ments, as such margin requirements generally range between 2% and

15%  of  contract face value.  Additionally, due to  the  use  of

leverage, the face value of the market sector instruments held by

the  Partnership is typically many times the total capitalization

of the Partnership.  The financial magnitude of the Partnership's

open  positions thus creates a "risk of ruin" not typically found

in  other investment vehicles.  Due to the relative size  of  the

positions   held,  certain  market  conditions  may   cause   the

Partnership  to incur losses greatly in excess of  VaR  within  a

short  period of time.  The foregoing VaR tables, as well as  the

past  performance of the Partnership, gives no indication of such

"risk  of  ruin".  In  addition,  VaR  risk  measures  should  be

interpreted  in  light  of the methodology's  limitations,  which

include  the following: past changes in market risk factors  will

not  always  yield accurate predictions of the distributions  and

correlations  of  future market movements; changes  in  portfolio

value  in  response  to  market movements  may  differ  from  the

responses implicit in a VaR model; published VaR results  reflect

past  trading  positions  while future  risk  depends  on  future

positions;  VaR  using  a  one-day time horizon  does  not  fully

capture the market risk of positions that cannot be liquidated or

hedged within one day; and the historical market risk factor data

used  for  VaR  estimation may provide only limited insight  into

losses  that  could  be  incurred under  certain  unusual  market

movements.



<PAGE>

The foregoing VaR tables present the results of the Partnership's

VaR for each of the Partnership's market risk exposures and on an

aggregate  basis  at June 30, 1999 and for the end  of  the  four

quarterly  reporting periods from July 1, 1998 through  June  30,

1999.   Since VaR is based on historical data, VaR should not  be

viewed  as  predictive  of  the  Partnership's  future  financial

performance or its ability to manage and monitor risk  and  there

can  be  no assurance that the Partnership's actual losses  on  a

particular day will not exceed the VaR amounts indicated or  that

such losses will not occur more than 1 in 100 trading days.



Non-Trading Risk

The  Partnership has non-trading market risk on its foreign  cash

balances not needed for margin.  However, such balances, as  well

as  any  market  risk  they may represent, are  immaterial.   The

Partnership  also maintains a substantial portion  (approximately

88%) of its available assets in cash at DWR.  A decline in short-

term interest rates will result in a decline in the Partnership's

cash  management  income. This cash flow risk is  not  considered

material.



Materiality,  as used throughout this section,  is  based  on  an

assessment  of  reasonably  possible  market  movements  and  the

potential  losses caused by such movements, taking  into  account

the   leverage,  optionality  and  multiplier  features  of   the

Partnership's market sensitive instruments.





<PAGE>

Qualitative Disclosures Regarding Primary Trading Risk Exposures

The following qualitative disclosures regarding the Partnership's

market risk exposures - except for (i) those disclosures that are

statements  of historical fact and (ii) the descriptions  of  how

the  Partnership  manages  its primary market  risk  exposures  -

constitute  forward-looking  statements  within  the  meaning  of

Section  27A  of  the  Securities Act  and  Section  21E  of  the

Securities  Exchange Act. The Partnership's primary  market  risk

exposures  as  well  as the strategies used and  to  be  used  by

Demeter  and the Trading Advisor for managing such exposures  are

subject  to numerous uncertainties, contingencies and risks,  any

one  of which could cause the actual results of the Partnership's

risk  controls to differ materially from the objectives  of  such

strategies.      Government    interventions,    defaults     and

expropriations,  illiquid  markets,  the  emergence  of  dominant

fundamental  factors, political upheavals, changes in  historical

price  relationships,  an  influx  of  new  market  participants,

increased  regulation  and many other  factors  could  result  in

material  losses  as  well as in material  changes  to  the  risk

exposures  and the risk management strategies of the Partnership.

Investors  must be prepared to lose all or substantially  all  of

their investment in the Partnership.



The  following  were the primary trading risk  exposures  of  the

Partnership  as of June 30, 1999, by market sector.   It  may  be

anticipated  however,  that  these  market  exposures  will  vary

materially over time.





<PAGE>

      Interest Rate. The primary market exposure in the  Partner-

ship  is in the interest rate sector.  Exposure was spread across

the  U.S., Japanese, German, British and Australian interest rate

sectors.   Interest rate movements directly affect the  price  of

the  sovereign bond futures positions held by the Partnership and

indirectly  affect  the  value of its stock  index  and  currency

positions.   Interest rate movements in one country  as  well  as

relative  interest  rate movements between  countries  materially

impact   the   Partnership's  profitability.   The  Partnership's

primary  interest  rate exposure is generally  to  interest  rate

fluctuations  in the United States and the other  G-7  countries.

However,  the  Partnership also takes futures  positions  in  the

government  debt  of  smaller nations - e.g. Australia.   Demeter

anticipates  that G-7 and Australian interest rates  will  remain

the  primary  interest rate exposure of the Partnership  for  the

foreseeable  future.  The changes in interest rates,  which  have

the most effect on the Partnership, are changes in long-term,  as

opposed  to  short-term, rates.  Most of the speculative  futures

positions  held  by  the Partnership are in  medium-to-long  term

instruments.  Consequently, even a material change in  short-term

rates  would  have  little effect on the  Partnership,  were  the

medium-to-long term rates to remain steady.

     Currency. The second largest market exposure this quarter is

in  the currency complex.  The Partnership's currency exposure is

to  exchange  rate  fluctuations,  primarily  fluctuations  which

disrupt  the  historical pricing relationships between  different

currencies and currency pairs.  Interest rate changes as well as

<PAGE>

political   and  general  economic  conditions  influence   these

fluctuations.   The  Partnership trades  in  a  large  number  of

currencies,  including cross-rates - i.e., positions between  two

currencies other than the U.S. dollar.  For the second quarter of

1999,  the  Partnership's major exposures were in  outright  U.S.

dollar positions.  (Outright positions consist of the U.S. dollar

vs.  other currencies.  These other currencies include the  major

and minor currencies).  Demeter does not anticipate that the risk

profile   of  the  Partnership's  currency  sector  will   change

significantly  in  the future.  The currency trading  VaR  figure

includes foreign margin amounts converted into U.S. dollars  with

an  incremental  adjustment to reflect  the  exchange  rate  risk

inherent to the dollar-based Partnership in expressing VaR  in  a

functional currency other than dollars.

      Equity.    The  primary equity exposure is to equity  price

risk in the G-7 countries.  The stock index futures traded by the

Partnership  are  by  law  limited to futures  on  broadly  based

indices.   As  of  June  30,  1999,  the  Partnership's   primary

exposures  were in the S&P 500 (U.S.), All Ordinaries (Australia)

and  Nikkei (Japan) stock indices.  The Partnership is  primarily

exposed to the risk of adverse price trends or static markets  in

the  U.S. and Japanese indices.  (Static markets would not  cause

major  market  changes  but  would  make  it  difficult  for  the

Partnership  to  avoid  being  "whipsawed"  into  numerous  small

losses).





     <PAGE>

     Commodity.

     Energy.  On June 30, 1999, the Partnership's energy exposure

was  shared  by  futures contracts in the  oil  and  natural  gas

markets.   Price movements in these markets result from political

developments  in  the  Middle East, weather patterns,  and  other

economic  fundamentals.  As oil prices have  broken  out  of  low

price  ranges  achieved in 1998, it is possible  that  volatility

will  increase as well.  Significant profits and losses have been

and  are  expected to continue to be experienced in this  market.

Natural gas, also a primary energy market exposure, has exhibited

more  volatility than the oil markets on an intra day  and  daily

basis and is expected to continue in this choppy pattern.

     Metals. The Partnership's primary metals market exposure  is

to  fluctuations in the price of gold and silver.   Although  the

Trading  Advisor will, from time to time, trade base metals  such

as copper, the principal market exposures of the Partnership have

consistently  been  in  precious metals, gold  and  silver.   The

Trading Advisor's gold trading has been increasingly limited  due

to  the long-lasting and mainly non-volatile decline in the price

of  gold over the last 10-15 years.  However, silver prices  have

remained  volatile over this period, and the Trading Advisor  has

from time to time taken substantial positions as perceived market

opportunities develop.  Demeter anticipates that gold and  silver

will   remain  the  primary  metals  market  exposure   for   the

Partnership.

     Soft  Commodities and Agriculturals.  On June 30, 1999,  the

Partnership   had  a  reasonable  amount  of  exposure   in   the

<PAGE>                              markets  that comprise  these

sectors.  Most of the exposure, however, was in the coffee, sugar

and corn markets.  Supply and demand inequalities, severe weather

disruption  and  market expectations affect  price  movements  in

these markets.



Qualitative Disclosures Regarding Non-Trading Risk Exposure

The  following  was  the only non-trading risk  exposure  of  the

Partnership as of June 30, 1999:



Foreign  Currency Balances.    The Partnership's primary  foreign

currency  balances  are in euros, Japanese yen,  British  pounds,

Swiss  francs and Canadian dollars. The Partnership controls  the

non-trading risk of these balances by regularly converting  these

balances  back  into dollars upon liquidation of  the  respective

position.



Qualitative Disclosures Regarding Means of Managing Risk Exposure

The  means  by  which  the Partnership and the  Trading  Advisor,

severally,  attempt to manage the risk of the Partnership's  open

positions  are  essentially the same  in  all  market  categories

traded.   Demeter  attempts  to manage the  Partnership's  market

exposure  by  (i)  diversifying the  Partnership's  assets  among

different  market  sectors  and  trading  approaches,  and  (ii),

monitoring  the  performance of the Trading Advisor  on  a  daily

basis.    In    addition,   the   Trading   Advisor   establishes

diversification guidelines, often set in terms of the maximum





<PAGE>

margin  to be committed to positions in any one market sector  or

market sensitive instrument.



Demeter monitors and controls the risk of the Partnership's  non-

trading   instrument,  cash,  which  is  the   only   Partnership

investment directed by Demeter, rather than the Trading Advisor.













































<PAGE>

                   PART II. OTHER INFORMATION



Item 1.   LEGAL PROCEEDINGS

The  following supplements Legal Proceedings previously disclosed

in the Partnership's 1998 Form 10-K:



With   respect   to  the  plaintiff's  consolidated   action   in

California, on July 1, 1999, the Superior Court of the  State  of

California, ruling from the bench, denied the plaintiffs'  motion

to have their lawsuit certified as a class action, stating, among

other  things,  that plaintiffs' lawsuit did not  present  common

questions of fact.



Item 6.   EXHIBITS AND REPORTS ON FORM 8-K

          (A)  Exhibits - None.

                         (B)  Reports on Form 8-K. - None.



























<PAGE>







                           SIGNATURE



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



                         Dean Witter Portfolio Strategy
                         Fund L.P. (Registrant)

                         By: Demeter Management Corporation
                             (General Partner)

August 13, 1999          By:  /s/ Lewis A. Raibley, III
                                  Lewis A. Raibley, III
                                  Director and Chief Financial
                                  Officer





The  General  Partner which signed the above is  the  only  party
authorized  to  act  for the Registrant.  The Registrant  has  no
principal   executive  officer,  principal   financial   officer,
controller, or principal accounting officer and has no  Board  of
Directors.








<TABLE> <S> <C>

<ARTICLE> 5
<LEGEND>
The schedule contains summary financial information extracted from Dean
Witter Portfolio Strategy Fund L.P. and is qualified in its entirety
by reference to such financial statements.
</LEGEND>

<S>                             <C>
<PERIOD-TYPE>                   6-MOS
<FISCAL-YEAR-END>                          DEC-31-1999
<PERIOD-END>                               JUN-30-1999
<CASH>                                     124,621,565
<SECURITIES>                                         0
<RECEIVABLES>                                  378,559<F1>
<ALLOWANCES>                                         0
<INVENTORY>                                          0
<CURRENT-ASSETS>                                     0
<PP&E>                                               0
<DEPRECIATION>                                       0
<TOTAL-ASSETS>                             136,328,112<F2>
<CURRENT-LIABILITIES>                                0
<BONDS>                                              0
                                0
                                          0
<COMMON>                                             0
<OTHER-SE>                                           0
<TOTAL-LIABILITY-AND-EQUITY>               136,328,112<F3>
<SALES>                                              0
<TOTAL-REVENUES>                            16,005,546<F4>
<CGS>                                                0
<TOTAL-COSTS>                                        0
<OTHER-EXPENSES>                             7,276,711
<LOSS-PROVISION>                                     0
<INTEREST-EXPENSE>                                   0
<INCOME-PRETAX>                              8,728,835
<INCOME-TAX>                                         0
<INCOME-CONTINUING>                          8,728,835
<DISCONTINUED>                                       0
<EXTRAORDINARY>                                      0
<CHANGES>                                            0
<NET-INCOME>                                 8,728,835
<EPS-BASIC>                                        0
<EPS-DILUTED>                                        0
<FN>
<F1>Receivables include interest receivable of $378,559.
<F2>In addition to cash and receivables, total assets include net
unrealized gain on open contracts of $11,327,988.
<F3>Liabilities include incentive fees payable of $1,541,384, redemptions
payable of $1,199,470, management fees payable of $454,076, and accrued
administrative expenses of $112,390.
<F4>Total revenues includes realized trading revenue of $15,412,575,
net change in unrealized of $(1,613,558) and interest income
of $2,206,529.
</FN>


</TABLE>


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