DEAN WITTER PORTFOLIO STRATEGY FUND LP
10-Q, 1999-05-14
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 period ended March 31, 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

                         March 31, 1999

<CAPTION>

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

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

     Statements of Operations for the Quarters Ended
     March 31, 1999 and 1998 (Unaudited)......................3

     Statements of Changes in Partners' Capital for the
     Quarters Ended March 31, 1999 and 1998 (Unaudited).......4

     Statements of Cash Flows for the Quarters Ended
     March 31, 1999 and 1998 (Unaudited)......................5

     Notes to Financial Statements (Unaudited) ............6-10

   Item 2.  Management's Discussion and Analysis
            of Financial Condition and Results of
            Operations....................................11-17

   Item 3.  Quantitative and Qualitative Disclosures
            about Market Risk . . . . . . . . . . . . . . 18-29

PART II. OTHER INFORMATION

   Item 1.  Legal Proceedings.............................   30

            Item  6.  Exhibits  and Reports on  Form  8-K........
            .........30





</TABLE>











<PAGE>
<TABLE>
                 PART I.  FINANCIAL INFORMATION
                                
Item 1.  Financial Statements

            DEAN WITTER PORTFOLIO STRATEGY FUND L.P.
               STATEMENTS OF FINANCIAL CONDITION

<CAPTION>
                                     March 31,     December 31,
                                        1999           1998
                                         $              $
                                    (Unaudited)
ASSETS
<S>                                  <C>            <C>
Equity in futures interests trading accounts:
 Cash                              122,498,124    119,724,918
 Net unrealized gain on open contracts          5,243,365          12,941,546

 Total Trading Equity              127,741,489    132,666,464

Interest receivable (DWR)              369,926        366,700


                                  Total Assets    128,111,415     133,033,164


LIABILITIES AND PARTNERS' CAPITAL

Liabilities

 Redemptions payable                 1,483,965      1,065,454
 Management fee payable                426,750        443,168
 Accrued administrative expenses        86,390         85,003
 Incentive fee payable                 -             305,087

 Total Liabilities                   1,997,105      1,898,712

Partners' Capital

 Limited Partners (48,387.820 and
  49,902.250 Units, respectively)  124,630,728   129,638,096
 General Partner (576 Units)         1,483,582      1,496,356

 Total Partners' Capital           126,114,310   131,134,452

  Total  Liabilities and Partners' Capital   128,111,415    133,0
33,164


NET ASSET VALUE PER UNIT              2,575.66         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 March 31,

                                       1999            1998
                                        $            $
REVENUES
<S>                          <C>             <C>
 Trading profit (loss):
    Realized                     8,418,966    4,798,524
    Net change in unrealized     (7,698,181)   (4,650,404)
      Total Trading Results               720,785        148,120
 Interest Income (DWR)           1,081,017      1,355,553
      Total Revenues             1,801,802     1,503,673

EXPENSES

   Brokerage   commissions   (DWR)       1,508,339      1,341,867
Management    fees                     1,288,183        1,319,880
Transaction   fees   and   costs           110,893        106,208
Administrative expenses             26,000          27,000
      Total Expenses             2,933,415     2,794,955

NET LOSS                         (1,131,613)   (1,291,282)

NET LOSS ALLOCATION

   Limited   Partners                  (1,118,839)    (1,269,287)
General Partner                     (12,774)     (21,995)

NET LOSS PER UNIT

   Limited   Partners                      (22.18)        (23.01)
General Partner                      (22.18)      (23.01)
<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 Quarters Ended March 31, 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               -                   (1,269,287)           (21,995)
(1,291,282)

Redemptions           (1,272.373)            (2,994,666)                     -
(2,994,666)

Partners' Capital
  March 31, 1998     55,032.872            $127,099,758          $2,246,938
$129,346,696



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

Net Loss               -                   (1,118,839)           (12,774)
(1,131,613)

Redemptions           (1,514.430)            (3,888,529)                  -
(3,888,529)

Partners' Capital
  March 31, 1999     48,963.820            $124,630,728          $1,483,582
$126,114,310


<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 Quarters Ended March 31,

                                       1999            1998
                                        $            $
CASH FLOWS FROM OPERATING ACTIVITIES
<S>                          <C>                         <C>
Net     loss                                          (1,131,613)
(1,291,282)
Noncash item included in net loss:
      Net  change  in  unrealized       7,698,181               4
,650,404
(Increase) decrease in operating assets:
     Interest receivable (DWR)         (3,226)             56,083
Due from DWR                           -                 (68,371)
Increase (decrease) in operating liabilities:
    Management fee payable           (16,418)            (16,093)
Accrued  administrative expenses       1,387               11,057
Incentive        fee       payable                      (305,087)
(801,115)
Net    cash   provided   by   operating   activities    6,243,224
2,540,683

CASH FLOWS FROM FINANCING ACTIVITIES

Increase in redemptions payable     418,511              275,029
Redemptions        of       units                     (3,888,529)
(2,994,666)
Net    cash   used   for   financing   activities     (3,470,018)
(2,719,637)
Net  increase  (decrease)  in  cash    2,773,206                (
178,954)

Balance      at      beginning     of     period      119,724,918
125,280,410
Balance      at      end     of     period            122,498,124
125,101,456


<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 has elected to adopt the provisions of SFAS  No.  133

beginning with the fiscal year 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 $5,243,365 and

$12,941,546   at   March  31,  1999  and   December   31,   1998,

respectively.

Of  the $5,243,365 net unrealized gain on open contracts at March

31,  1999 $4,320,541 related to exchange-traded futures contracts

and  $922,824  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

March  31,  1999 and December 31, 1998 mature through March  2000

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

currency contracts held by the Partnership at March 31, 1999  and

December

<PAGE>

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


31, 1998 mature through June 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 $126,818,665 and $133,599,774 at March 31,

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 Ended March 31, 1999

For  the  quarter  ended March 31, 1999 the Partnership  recorded

trading  revenues  including interest income  of  $1,801,802  and

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

significant  losses  were recorded in the  global  interest  rate

futures  markets.   During  January  and  February,  losses  were

recorded  from  short Japanese bond futures positions  as  prices

increased sharply due to an announcement by the Japanese Ministry

of  Finance that they would resume outright purchases of JGBs and

on  growing  speculation that the Bank of  Japan  may  underwrite

Japanese government bonds.  Fears that the recent rise in

<PAGE>

Japanese  bond yields would lead many Japanese money managers  to

repatriate  assets  from foreign investments  to  yen-denominated

debt  also  pushed  prices higher.  Losses were also  experienced

from  long  Japanese government bond futures  positions  as  bond

prices  dropped  during mid-March as bond yields  rose  following

comments by Bank of Japan Governor Masaru Hayami that he expected

interest rates in Japan to rise over time.  Offsetting gains were

recorded  during February from short positions in  U.S.  interest

rate  futures as domestic bond prices moved lower due  to  strong

economic  data  and the subsequent possibility of inflation.   In

the metals markets, losses were recorded 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.  Additional losses were recorded

from  short  gold futures positions as prices rose to  a  2-month

high  early  in March on short-covering by speculative investment

funds.   In  soft commodities, losses were recorded during  March

from  short  coffee futures positions as prices surged  in  late-

March  as options-related buying triggered waves of buy-stops  at

several key resistance levels, attracting fund short-covering.  A

majority  of these losses was offset by gains recorded throughout

the quarter in the currency markets from short euro positions  as

the  value  of the U.S. dollar hit new highs versus the  European

common  currency  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.   In  the

energy  markets, gains were recorded from long crude and  heating

oil futures positions as oil prices moved significantly higher

<PAGE>

amid  a substantial recovery in oil prices during March that  was

largely  attributed  to  the news that  both  OPEC  and  non-OPEC

countries  had  reached  an agreement  to  cut  total  output  by

approximately two million barrels a day beginning April 1st.   In

the  global  stock  index futures markets,  gains  were  recorded

during  March  from  long positions in ASE All  Ordinaries  Index

futures as Australian stock prices increased in response  to  the

historic  price  levels reached by U.S. equities and  on  growing

optimism  regarding the economic well being of the  Pacific  Rim.

Interest income decreased by approximately $275,000 for the three

months  ended  March 31, 1999 as compared to the same  period  in

1998 primarily due to declines in interest rates on U.S. Treasury

bills.  Total expenses for the three months ended March 31,  1999

were $2,933,415 resulting in a net loss of $1,131,613.  The value

of  a  Unit  decreased  from $2,597.84 at December  31,  1998  to

$2,575.66 at March 31, 1999.



For the Quarter Ended March 31, 1998

For  the  quarter ended March 31, 1998, the Partnership  recorded

total  trading  revenues including interest income of  $1,503,673

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

significant  losses  were recorded in the  metals  markets  as  a

result  of  choppy  price  movement in gold  futures  during  the

quarter,  as  well  as from long silver futures positions  during

March,  as  silver  prices reversed lower after  trending  higher

previously.  In currencies, losses recorded from short  positions

in the Japanese yen as its value increased versus the U.S. dollar

                                

<PAGE>

during  January  and early February more than offset  gains  from

short  positions in the Swiss franc and German mark during March.

In  the agricultural markets, losses were experienced from  short

corn  futures  positions during January  and  March.   Additional

losses  were recorded in global stock index futures from  trading

Nikkei  Index futures during January and March as Japanese equity

prices moved in a choppy pattern as the stability of the Japanese

economy  remained  in question.  A portion of  the  Partnership's

overall losses was offset by gains recorded in the energy markets

from  short  positions in crude oil futures as oil  prices  moved

downward throughout a majority of the quarter despite a potential

conflict  in  the  Persian Gulf during  February.   In  financial

futures, gains recorded from long positions in German and  French

interest  rate  futures  more  than offset  losses  from  trading

Japanese  and  U.S.  interest rate futures  during  the  quarter.

Total  expenses for the three months ended March  31,  1998  were

$2,794,955, resulting in a net loss of $1,291,282. The value of a

Unit  decreased from $2,373.36 at December 31, 1997 to  $2,350.35

at March 31, 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

<PAGE>

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.

     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.



<PAGE>

    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.

                                
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.

                                
                                
                                
                                
                                
                                
                                
                                
                                
<PAGE>
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

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.

                                

<PAGE>

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

Partnership'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 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.

                                

<PAGE>

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")  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.

<PAGE>

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 March 31, 1999.  As of March 31,  1999,

the  Partnership's  total capitalization was  approximately  $126

million.

     Primary Market             March 31, 1999
     Risk Category              Value at Risk

     Interest Rate                 (1.50)%

     Currency                      (2.88)

     Equity                        (0.57)

      Commodity                         (0.63)

      Aggregate Value at Risk      (3.42)%


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  March  31,  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

<PAGE>

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 April 1,

1998 through March 31, 1999.

Primary Market Risk Category        High      Low      Average

Interest Rate                      (2.24)%   (1.50)%   (1.97)%

Currency                           (2.88)    (1.16)    (1.97)

Equity                             (0.57)    (0.34)    (0.41)

Commodity                          (0.83)    (0.60)    (0.67)

Aggregate Value at Risk            (3.42)%   (2.27)%   (2.87)%

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

<PAGE>

"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.



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 March 31, 1999 and for the end  of  the  four

quarterly reporting periods from April 1, 1998 through March  31,

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

<PAGE>

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.



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

<PAGE>

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 March 31, 1999, by market sector.   It  may  be

anticipated  however,  that  these  market  exposures  will  vary

materially over time.

  Interest  Rate.  Interest rate risk  is  the  principal  market

exposure  of  the Partnership.  Interest rate movements  directly

affect the price of the sovereign bond futures positions held  by

the  Partnership and indirectly 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 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  interest rates will  remain  the  primary

market  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

<PAGE>

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 Partnership's currency exposure is to  exchange

rate  fluctuations,  primarily  fluctuations  which  disrupt  the

historical pricing relationships between different currencies and

currency  pairs.  These fluctuations are influenced  by  interest

rate   changes   as  well  as  political  and  general   economic

conditions. The Partnership's major exposures have typically been

in  the  dollar/yen, dollar/pound, dollar/euro  and  dollar/Swiss

francs  positions.   Demeter does not anticipate  that  the  risk

profile   of  the  Partnership's  currency  sector  will   change

significantly  in  the future, although it is difficult  at  this

point  to predict the effect of the introduction of the  Euro  on

the Trading Advisor's currency trading strategies.

  Equity. The Partnership's 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  March  31,  1999,  the  Partnership's  primary

exposures were in the Nikkei (Japan), ASE (Australia) and S&P 500

stock indices.  The Partnership is primarily exposed to the  risk

of  adverse  price trends or static markets in  the  major  U.S.,

European  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.

     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 the 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.   The  Partnership's

primary  commodities exposure is to fluctuations in the price  of

soft  commodities  and agriculturals, which  are  often  directly

affected  by  severe  or unexpected weather conditions.   Coffee,

corn, sugar and cotton accounted for the substantial bulk of  the

Partnership's  commodities exposure as of March  31,  1999.   The

Partnership has market exposure to live cattle.  However, Demeter

anticipates  that the Trading Advisors will maintain an  emphasis

on  coffee,  corn, sugar and cotton in which the Partnership  has

historically taken it's largest positions.

      Energy. The Partnership's primary energy market exposure is

to  gas  and oil price movements, often resulting from  political

developments in the Middle East.  Although the Trading Advisor

<PAGE>

trades  natural  gas  to a limited extent,  oil  is  by  far  the

dominant  energy market exposure of the Partnership.  Oil  prices

are currently depressed, but they can be volatile and substantial

profits and losses have been and are expected to continue  to  be

experienced in this market.

                                

Qualitative Disclosures Regarding Non-Trading Risk Exposure

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

Partnership as of March 31, 1999:

                                

Foreign  Currency  Balances.  The Partnership's  primary  foreign

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

Swiss francs, and German mark.  The Partnership controls the non-

trading  risk  of  these balances by regularly  converting  these

balances  back into U.S. dollars at varying intervals,  depending

upon such factors as size, volatility, etc.



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 Item 3. of the Partnership's  1998 Form 10-K:



On  April  12,  1999,  the  defendants  filed  a  motion  in  the

California  action to oppose certification by the  court  of  the

class in the California litigation.



With  respect  to JWH, the New York Supreme Court  complaint  was

dismissed  with prejudice when the plaintiffs failed  to  replead

against  JWH in December, 1998.  Further, JWH has been  dismissed

as  a  defendant  in  the  California actions  without  prejudice

pursuant  to  a  tolling  agreement with plaintiffs  executed  in

January, 1999.



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)

May 14, 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>                   3-MOS
<FISCAL-YEAR-END>                          DEC-31-1999
<PERIOD-END>                               MAR-31-1999
<CASH>                                     122,498,124
<SECURITIES>                                         0
<RECEIVABLES>                                  369,926<F1>
<ALLOWANCES>                                         0
<INVENTORY>                                          0
<CURRENT-ASSETS>                                     0
<PP&E>                                               0
<DEPRECIATION>                                       0
<TOTAL-ASSETS>                             128,111,415<F2>
<CURRENT-LIABILITIES>                                0
<BONDS>                                              0
                                0
                                          0
<COMMON>                                             0
<OTHER-SE>                                           0
<TOTAL-LIABILITY-AND-EQUITY>               128,111,415<F3>
<SALES>                                              0
<TOTAL-REVENUES>                             1,801,802<F4>
<CGS>                                                0
<TOTAL-COSTS>                                        0
<OTHER-EXPENSES>                             2,933,415
<LOSS-PROVISION>                                     0
<INTEREST-EXPENSE>                                   0
<INCOME-PRETAX>                            (1,131,613)
<INCOME-TAX>                                         0
<INCOME-CONTINUING>                        (1,131,613)
<DISCONTINUED>                                       0
<EXTRAORDINARY>                                      0
<CHANGES>                                            0
<NET-INCOME>                               (1,131,613)
<EPS-PRIMARY>                                        0
<EPS-DILUTED>                                        0
<FN>
<F1>Receivables include interest receivable of $369,926.
<F2>In addition to cash and receivables, total assets include net
unrealized gain on open contracts of $5,243,365.
<F3>Liabilities include redemptions payable of $1,483,965, management
fees payable of $426,750, and accrued administrative expenses of $86,390.
<F4>Total revenues includes realized trading revenue of $8,418,966,
net change in unrealized of $(7,698,181) and interest income
of $1,081,017.
</FN>
        

</TABLE>


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