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 March 31, 2000 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. 0-24035

        MORGAN STANLEY DEAN WITTER SPECTRUM COMMODITY FUND L.P.
     (Exact name of registrant as specified in its charter)


          Delaware                              13-3968008
(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


              Morgan Stanley Tangible Asset Fund L.P.
(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>
    MORGAN STANLEY DEAN WITTER SPECTRUM COMMODITY FUND L.P.
      (formerly "Morgan Stanley Tangible Asset Fund L.P.")
             INDEX TO QUARTERLY REPORT ON FORM 10-Q

                       March 31, 2000

<CAPTION>

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

     Statements of Financial Condition March 31, 2000
     (Unaudited) and December 31, 1999......................... 2

     Statements of Operations for the Quarters Ended
     March 31, 2000 and 1999 (Unaudited)....................... 3

     Statements of Changes in Partners' Capital for the
        Quarters Ended March 31, 2000 and 1999

(Unaudited)............................................... 4

     Statements of Cash Flows for the Quarters Ended
     March 31, 2000 and 1999 (Unaudited)........................5

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

Item 2. Management's Discussion and Analysis of

Financial Condition and Results of Operations.......11-15

Item 3. Quantitative and Qualitative Disclosures about
        Market Risk ........................................16-25

Part II. OTHER INFORMATION

Item 1. Legal Proceedings..................................... 26

Item 2. Changes in Securities and Use of Proceeds...........26-28

Item 5. Other Information..................................... 28

Item 6. Exhibits and Reports on Form 8-K.......................28


</TABLE>






<PAGE>
<TABLE>
                 PART I.  FINANCIAL INFORMATION

Item 1.  Financial Statements

     MORGAN STANLEY DEAN WITTER SPECTRUM COMMODITY FUND L.P.
      (formerly "Morgan Stanley Tangible Asset Fund L.P.")
               STATEMENTS OF FINANCIAL CONDITION
<CAPTION>
                                     March 31,     December 31,
                                        2000           1999
                                         $              $
                                    (Unaudited)
ASSETS
<S>                                   <C>              <C>
Equity in futures interests trading accounts:
 Cash                             23,480,160      23,430,137

     Net unrealized loss on open contracts (MS & Co.)(461,517)         (100,830)
       Net  unrealized  gain  (loss)  on  open  contracts  (MSIL)
(94,573)                             643,258

 Total unrealized gain (loss) on open contracts     (556,090)          542,428

      Total Trading Equity        22,924,070     23,972,565

Interest receivable (MS & Co.)        85,776            76,192
Subscriptions receivable              85,600              -

      Total Assets                23,095,446     24,048,757


LIABILITIES AND PARTNERS' CAPITAL

Liabilities

 Redemptions payable                 368,850        269,545
 Accrued brokerage fees (MS & Co. and MSIL)68,985    70,827
 Accrued management fee (MSCM)        47,250         48,511
 Service fee payable (Demeter)        18,900         19,404

      Total Liabilities              503,985        408,287


Partners' Capital

 Limited Partners (2,908,338.656 and
       3,062,471.522 Units, respectively)22,259,327  23,310,162
  General  Partner (43,395.648 Units)       332,134            33
0,308

 Total Partners' Capital          22,591,461     23,640,470

  Total  Liabilities and Partners' Capital   23,095,446      24,0
48,757

NET ASSET VALUE PER UNIT                7.65               7.61
<FN>
          The accompanying notes are an integral part
                 of these financial statements.
</TABLE>
<PAGE>
<TABLE>
    MORGAN STANLEY DEAN WITTER SPECTRUM COMMODITY FUND L.P.
      (formerly "Morgan Stanley Tangible Asset Fund L.P.")
                    STATEMENTS OF OPERATIONS
                           (Unaudited)

<CAPTION>



For the Quarters Ended March 31,

                                       2000            1999
                                        $            $
REVENUES
<S>                        <C>               <C>
 Trading profit (loss):
    Realized                      1,395,164    34,855
                       Net  change  in  unrealized    (1,098,518)
796,011
      Total Trading Results         296,646   830,866
    Interest Income (MS & Co.)       256,714       208,595
      Total Revenues                553,360     1,039,461

EXPENSES

     Brokerage   fees   (MS  &  Co.  and  MSIL)213,906    215,094
 Management    fees    (MSCM)               146,511       147,325
 Service   fees   (Demeter)               58,604           58,930
 Total Expenses                    419,021       421,349

NET INCOME                          134,339      618,112

NET INCOME ALLOCATION

       Limited    Partners                  132,513       609,955
General Partner                       1,826      8,157

NET INCOME PER UNIT

       Limited    Partners                       .04          .19
General Partner                         .04       .19


<FN>


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

<PAGE>
<TABLE>
    MORGAN STANLEY DEAN WITTER SPECTRUM COMMODITY FUND L.P.
      (formerly "Morgan Stanley Tangible Asset Fund L.P.")
           STATEMENTS OF CHANGES IN PARTNERS' CAPITAL
        For the Quarters Ended March 31, 2000 and 1999
                          (Unaudited)

<CAPTION>



                          Units of
                        Partnership Limited   General
                          Interest   Partners Partner    Total




<S>        <C>                             <C>                   <C>
<C>
Partners' Capital,
  December 31, 1998 3,788,464.700          $24,622,999           $285,317
$24,908,316

Net Income             -                   609,955       8,157        618,112

Redemptions         (290,241.586)                (1,868,777)             -
(1,868,777)

Partners' Capital,
 March 31, 1999   3,498,223.114            $23,364,177           $293,474
$23,657,651




Partners' Capital,
  December 31, 19993,105,867.170           $23,310,162           $330,308
$23,640,470

Offering of Units    11,189.544            85,600        -            85,600

Net Income                 -               132,513               1,826
134,339

Redemptions         (165,322.410)              (1,268,948)               -
(1,268,948)

Partners' Capital,
 March 31, 2000   2,951,734.304            $22,259,327           $332,134
$22,591,461




<FN>

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





<PAGE>
<TABLE>
    MORGAN STANLEY DEAN WITTER SPECTRUM COMMODITY FUND L.P.
      (formerly "Morgan Stanley Tangible Asset Fund L.P.")
                    STATEMENTS OF CASH FLOWS
                           (Unaudited)

<CAPTION>




                                For the Quarters Ended March 31,

                                       2000            1999
                                        $              $
CASH FLOWS FROM OPERATING ACTIVITIES
<S>                             <C>          <C>
    Net    income                           134,339       618,112
Noncash item included in net income:
    Net change in unrealized      1,098,518     (796,011)
 (Increase) decrease in operating assets:
    Interest receivable (MS & Co.)    (9,584)     8,305
Decrease in operating liabilities:
     Accrued  brokerage  fees  (MS &  Co.  and  MSIL)     (1,842)
(13,928)
Accrued management fee (MSCM)         (1,261)     (9,540)
    Service fee payable (Demeter)           (504)     (3,816)
 Net cash provided by (used for) operating activities   1,219,666
(196,878)

CASH FLOWS FROM FINANCING ACTIVITIES

   Redemptions  of  Units              (1,268,948)    (1,868,777)
Increase   (decrease)  in  redemptions  payable99,305   (509,401)
Offering of Units                    85,600      -
 Increase in subscriptions receivable      (85,600)            -

  Net  cash  used  for  financing  activities    (1,169,643)   (2
,378,178)

 Net increase (decrease) in cash     50,023   (2,575,056)
 Balance at beginning of period   23,430,137     26,519,891
 Balance at end of period        23,480,160    23,944,835
<FN>



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



<PAGE>
     MORGAN STANLEY DEAN WITTER SPECTRUM COMMODITY FUND L.P.

      (formerly "Morgan Stanley Tangible Asswet 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 Morgan  Stanley  Dean

Witter  Spectrum  Commodity Fund L.P. (formerly, "Morgan  Stanley

Tangible  Asset Fund L.P.") (the "Partnership").   The  financial

statements  and  condensed  notes  herein  should  be   read   in

conjunction  with  the  Partnership's December  31,  1999  Annual

Report on Form 10-K.



1. Organization

Morgan Stanley Dean Witter Spectrum Commodity Fund L.P. (formerly

Morgan  Stanley  Tangible  Asset  Fund)  is  a  Delaware  limited

partnership organized to engage primarily in speculative  trading

of  futures contracts in metals, energy and agricultural markets,

(collectively,  "futures interests").   On  March  1,  2000,  the

Partnership became one of the Morgan Stanley Dean Witter Spectrum

Series of funds, comprised of Morgan Stanley Dean Witter Spectrum

Global  Balanced L.P., Morgan Stanley Dean Witter Spectrum Select

L.P.,  Morgan  Stanley Dean Witter Spectrum  Strategic  L.P.  and

Morgan Stanley Dean Witter Spectrum Technical L.P. (collectively,

the "Spectrum Series").  The Partnership's general partner is

<PAGE>

     MORGAN STANLEY DEAN WITTER SPECTRUM COMMODITY FUND L.P.
      (formerly "Morgan Stanley Tangible Asset Fund L.P.")
            NOTES TO FINANCIAL STATEMENTS (CONTINUED)




Demeter   Management  Corporation  ("Demeter").   The   commodity

brokers  are Morgan Stanley & Co. Incorporated ("MS &  Co.")  and

Morgan    Stanley   &   Co.   International   Limited   ("MSIL"),

(collectively, the "Commodity Brokers").  The trading advisor  is

Morgan  Stanley  Commodities  Management,  Inc.  ("MSCM"  or  the

"Trading Advisor").  MSCM, the Commodity Brokers and Demeter  are

all wholly-owned subsidiaries of Morgan Stanley Dean Witter & Co.



2.  Related Party Transactions

The  Partnership's cash is on deposit with the Commodity  Brokers

in futures interests trading accounts to meet margin requirements

as  needed.  MS  & Co. pays interest on these funds  based  on  a

prevailing  rate  on  U.S. Treasury bills. The  Partnership  pays

brokerage  fees  to  the Commodity Brokers, management  fees  and

incentive  fees  (if  applicable) to MSCM, and  service  fees  to

Demeter.



3.  Financial Instruments

The  Partnership trades futures and forward contracts in  metals,

energy  and agricultural markets.  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

<PAGE>

     MORGAN STANLEY DEAN WITTER SPECTRUM COMMODITY FUND L.P.
      (formerly "Morgan Stanley Tangible Asset Fund L.P.")
            NOTES TO FINANCIAL STATEMENTS (CONTINUED)


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 ("FASB")

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.   In  June 1999, the FASB issued SFAS No. 137,  "Accounting

for  Derivative Instruments and Hedging Activities - Deferral  of

the  Effective Date of SFAS No. 133," which defers  the  required

implementation of SFAS No. 133 until fiscal years beginning after

June  15, 2000.  However, the Partnership had previously  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  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.



<PAGE>
     MORGAN STANLEY DEAN WITTER SPECTRUM COMMODITY FUND L.P.
      (formerly "Morgan Stanley Tangible Asset Fund L.P.")
            NOTES TO FINANCIAL STATEMENTS (CONTINUED)


The  net unrealized gains (losses) on open contracts are reported

as  a component of "Equity in futures interests trading accounts"

on  the  Statements of Financial Condition and totaled $(556,090)

and   $542,428  at  March  31,  2000  and  December   31,   1999,

respectively.



The  $556,090 net unrealized loss on open contracts at March  31,

2000  and  the $542,428 net unrealized gain on open contracts  at

December  31,  1999  were  related  to  exchange-traded   futures

contracts that mature through April 2000.



The Partnership has 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.



The  Partnership also has credit risk because MS & Co.  and  MSIL

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 MS  &

Co.   and  MSIL,  as  a  futures  commission  merchant  for   the

Partnership's




<PAGE>
     MORGAN STANLEY DEAN WITTER SPECTRUM COMMODITY FUND L.P.
      (formerly "Morgan Stanley Tangible Asset Fund L.P.")
            NOTES TO FINANCIAL STATEMENTS (CONCLUDED)




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 (loss) on all open futures  contracts,

which   funds,   in   the  aggregate,  totaled  $22,924,070   and

$23,972,565   at   March  31,  2000  and   December   31,   1999,

respectively.






























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


Liquidity  -   The  Partnership  deposits  its  assets  with  the

Commodity   Brokers,   in  separate  futures   trading   accounts

established  for the Trading Advisor, which assets  are  used  as

margin  to engage in trading. The assets are held in either  non-

interest  bearing bank accounts or in securities and  instruments

permitted  by  the CFTC for investment of customer segregated  or

secured  funds.  The Partnership's assets held by  the  Commodity

Brokers  may  be  used  as margin solely  for  the  Partnership's

trading.   Since the Partnership's sole purpose is  to  trade  in

futures  and  forwards, it is expected that the Partnership  will

continue to own such liquid assets for margin purposes.



The  Partnership's investment in futures and forwards  may,  from

time  to  time,  be illiquid.  Most U.S. futures exchanges  limit

fluctuations  in  prices  during  a  single  day  by  regulations

referred  to  as  "daily  price fluctuations  limits"  or  "daily

limits".   Trades may not 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  that  futures contract can neither  be  taken  nor

liquidated  unless  traders are willing to effect  trades  at  or

within  the  limit.  Futures prices have occasionally  moved  the

daily  limit  for  several consecutive days  with  little  or  no

trading.  These market conditions could



<PAGE>

prevent  the  Partnership from promptly liquidating  its  futures

contracts and result in restrictions on redemptions.



The  Partnership  has  never had illiquidity  affect  a  material

portion of its assets.



Capital  Resources. The Partnership does not have, or  expect  to

have,  any capital assets.  Redemptions, exchanges and  sales  of

additional  units of limited partnership interest ("Unit(s)")  in

the  future  will  affect  the  amount  of  funds  available  for

investments  in futures interests in subsequent periods.   It  is

not possible to estimate the amount, and therefore, the impact of

future redemptions of Units.



Results of Operations

General.  The Partnership's results depend on its Trading Advisor

and the ability of the Trading Advisor's trading programs to take

advantage of price movements or other profit opportunities in the

futures  and forwards markets.  The following presents a  summary

of  the Partnership's operations for the three months ended March

31,  2000 and 1999, respectively, and a general discussion of its

trading activities during each period.  It is important to  note,

however,  that the Trading Advisor trades in various  markets  at

different  times  and that prior activity in a particular  market

does  not  mean that such market will be actively traded  by  the

Trading   Advisor   or  will  be  profitable   in   the   future.

Consequently,

<PAGE>

the  results  of operations of the Partnership are  difficult  to

discuss  other  than  in  the context of  its  Trading  Advisor's

trading  activities on behalf of the Partnership as a  whole  and

how the Partnership has performed in the past.



For the Quarter Ended March 31, 2000

For  the  quarter ended March 31, 2000, the Partnership  recorded

trading  revenues,  including interest income,  of  $553,360  and

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

significant  gains of approximately 4.3% were recorded  primarily

during  January  and  February in the energy  markets  from  long

futures  positions in crude oil and its refined products  as  oil

prices increased on concerns about future output levels from  the

world's leading producer countries amid dwindling stockpiles  and

increasing  demand.   In  the  agricultural  markets,  gains   of

approximately  2.1% were recorded earlier in January  from  short

positions  in corn and soybean futures as prices moved higher  on

increasing concerns for dryness in Brazil, subsequent crop damage

and  a surprise cut in year-end stocks.  During March, gains were

recorded  from  long  futures positions  in  corn,  soybeans  and

soybean  related  products as prices in these  markets  increased

amid  fears of a drought this summer.  These gains were partially

offset  by  losses of approximately 2.8% recorded in  the  metals

markets from long aluminum and copper futures positions as prices

reversed  lower earlier in February due primarily to  technically

based selling.  Aluminum and copper prices dipped further later

<PAGE>

in  February led downward by falling prices of other base metals.

Losses   were  recorded  during  March  from  long  gold  futures

positions  as  gold prices fell on fears that the French  central

bank  could  decide  to  sell some  of  its  reserves.   In  soft

commodities, losses of approximately 2.3% were recorded primarily

during January and February from long coffee futures positions as

coffee prices declined in the wake of forecasts for a bumper crop

in  Brazil.  Long positions in sugar futures also incurred losses

during  January  and  February as prices dropped  amid  sustained

fears  of a global supply surplus.  Total expenses for the  three

months  ended  March  31, 2000 were $419,021,  resulting  in  net

income of $134,339.  The value of a Unit increased from $7.61  at

December 31, 1999 to $7.65 at March 31, 2000.



For the Quarter Ended March 31, 1999

For  the  quarter ended March 31, 1999, the Partnership  recorded

total  trading  revenues including interest income of  $1,039,461

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

Partnership's  long-only  trading  approach  recorded  its   most

significant  gains  of approximately 6.5% in the  energy  markets

primarily  during March from long futures positions in crude  oil

and  its refined products, heating oil and unleaded gasoline,  as

oil  prices moved considerably higher.  The substantial  recovery

in  oil  prices during March 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

<PAGE>

beginning April 1, 1999.  Additional gains of approximately  0.5%

were  recorded  in the livestock markets throughout  the  quarter

from  long positions in feeder and live cattle futures as  prices

moved  higher  on  plans  for government  aid  programs  to  help

struggling farmers.  A portion of the Partnership's overall gains

for  the  quarter  was  offset by losses  of  approximately  2.0%

experienced  in soft commodities largely from long  positions  in

cocoa,  sugar  and  coffee  futures as prices  in  these  markets

declined  significantly throughout the quarter  amid  fears  that

economic  turmoil in Brazil would lead them to flood  the  market

with  increased  exports.  Additional losses were  recorded  from

long  positions in orange juice futures during February as prices

plummeted  to  a 13-month low in response to a USDA  report  that

unexpectedly  raised  Florida and U.S. crop  estimates.   In  the

metals markets, losses of approximately 1.0% were recorded mainly

from  long  copper  futures positions during  January  as  prices

declined  on reports of a large rise in copper warehouse  stocks.

Smaller  losses  of  approximately 0.7% were experienced  in  the

agricultural  markets during January and February primarily  from

long  positions in soybean and soybean oil futures as  prices  in

these  markets moved lower due to beneficial growing  weather  in

South  America and speculation that Brazil would increase exports

to  aid  its ailing economy.  Total expenses for the three months

ended  March 31, 1999 were $421,349, resulting in net  income  of

$618,112.   The value of a Unit increased from $6.57 at  December

31, 1998 to $6.76 at March 31, 1999.

<PAGE>

Item  3.  QUANTITATIVE AND QUALITATIVE DISCLOSURES  ABOUT  MARKET
RISK

Introduction

The  Partnership is a commodity pool involved in the  speculative

trading  of  futures interests.  The market-sensitive instruments

held  by  the  Partnership are acquired  solely  for  speculative

trading purposes only and, as a result, all or substantially  all

of  the Partnership's assets are at risk of trading loss.  Unlike

an operating company, the risk of market-sensitive instruments is

central,  not  incidental,  to  the Partnership's  main  business

activities.



The  futures interests traded by the Partnership involve  varying

degrees  of  market  risk.  Market risk is often  dependent  upon

changes  in  the level or volatility of interest rates,  exchange

rates,  and  prices  of  financial instruments  and  commodities.

Fluctuations  in market risk based upon these 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  among  the

Partnership's open positions, the volatility present  within  the

markets,  and the liquidity of the markets.  At different  times,

each  of these factors may act to increase or decrease the market

risk associated with the Partnership.

<PAGE>

The  Partnership's past performance is not necessarily indicative

of  its future results.  Any attempt to numerically quantify  the

Partnership's  market risk is limited by the uncertainty  of  its

speculative  trading.  The Partnership's speculative trading  may

cause future losses and volatility (i.e. "risk of ruin") that far

exceed  the  Partnership's experiences to date or any  reasonable

expectations based upon historical changes in market value.



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 using mark-to-market

accounting  principles.   Any loss in the  market  value  of  the

Partnership's  open  positions  is  directly  reflected  in   the

Partnership's earnings, whether realized or unrealized, and  cash

flow.   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 market sectors traded  by

the  Trading Advisor is estimated below in terms of Value at Risk

("VaR").  The  VaR  model used by the Partnership  includes  many

variables that could change the market value of the Partnership's

trading  portfolio.  The Partnership estimates VaR using a  model

based upon historical simulation with a confidence level of  99%.

Historical  simulation involves constructing  a  distribution  of

hypothetical  daily changes in the value of a trading  portfolio.

The  VaR  model 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, and correlation among these variables.



The  hypothetical changes in portfolio value are based  on  daily

percentage changes observed in key market indices or other market

factors  ("market  risk  factors")  to  which  the  portfolio  is

sensitive.    The   historical   observation   period   of    the

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

confidence  level  of the Partnership's VaR  corresponds  to  the

negative change in portfolio value that, based on observed market

risk factors, would have been exceeded once in 100 trading days.



VaR   models,   including  the  Partnership's,  are  continuously

evolving  as trading portfolios become more diverse and  modeling

techniques  and systems capabilities improve.  Please  note  that

the VaR model is used to numerically quantify market risk for

<PAGE>

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  tables  indicates the  VaR  associated  with  the

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

by primary market risk category as of March 31, 2000 and 1999. As

of   March   31,   2000   and  1999,  the   Partnership's   total

capitalization  was approximately $23 million  and  $24  million,

respectively.

      Primary Market            March 31, 2000          March 31,
1999
     Risk Category             Value at Risk      Value at Risk

     Commodity                     (2.10)%            (1.78)%


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

positions  at March 31, 2000 and 1999 only and is not necessarily

representative  of  either the historic  or  future  risk  of  an

investment  in  the  Partnership. Because the Partnership's  only

business  is  the speculative trading of futures  interests,  the

composition  of  its  trading portfolio can change  significantly

over  any given time period, or even within a single trading day.

Any  changes  in  open positions could positively  or  negatively

materially impact market risk as measured by VaR.







<PAGE>

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,

1999 through March 31, 2000.



Primary Market Risk Category        High      Low     Average

Commodity                          (2.10)%   (1.78)%   (1.95)%


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

requirements.  Margin requirements generally range between 2% and

15%  of  contract face value. Additionally, the use  of  leverage

causes  the face value of the market sector instruments  held  by

the   Partnership   to  typically  be  many   times   the   total

capitalization   of   the  Partnership.    The   value   of   the

Partnership's open positions thus creates a "risk  of  ruin"  not

typically found in other investments.  The relative size  of  the

positions held may cause the Partnership to incur losses  greatly

in excess of VaR within a short period of time, given the effects

of  the  leverage employed and market volatility.  The VaR tables

above, as well as the past performance of the Partnership,  gives

no indication of such "risk of ruin". In addition, VaR risk

measures   should  be  viewed  in  light  of  the   methodology's

limitations, which include the following:



<PAGE>

     past  changes in market risk factors will not always result

  in accurate predictions of the distributions and correlations of

  future market movements;

     changes  in portfolio value in response to market movements

  may differ from those of the VaR model;

    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 VaR tables above present the results of the Partnership's VaR

for the Partnership's market risk exposures at March 31, 2000 and

for the end of the four quarterly reporting periods from April 1,

1999  through  March 31, 2000.  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 or monitor

risk.   There  can be no assurance that the Partnership's  actual

losses  on  a  particular  day will not exceed  the  VaR  amounts

indicated above or that such losses will not occur more than 1 in

100 trading days.



    <PAGE>
Non-Trading Risk

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

balances  not needed for margin.  These balances and  any  market

risk  they  may  represent are immaterial.  The Partnership  also

maintains  a  substantial  portion  (approximately  93%)  of  its

available  assets  in cash at MS & Co.  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  any

associated  potential losses, 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 (A) those disclosures that are

statements of historical fact and (B) 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

<PAGE>

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   expro-

priations,   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  is  the  primary trading  risk  exposure  of  the

Partnership as of March 31, 2000, by market sector.   It  may  be

anticipated  however, that market exposures will vary  materially

over time.



Commodity

Metals -  The Partnership's primary metals market exposure is  to

fluctuations  in  the price of gold and silver.  The  Partnership

will  from time to time trade base metals such as copper, nickel,

aluminum and zinc however, the principal market exposures of  the

Partnership have consistently been in precious metals,  gold  and

silver  (and,  to a much lesser extent, platinum).  A  reasonable

amount of exposure was evident in the gold market as gold prices

<PAGE>

were  volatile  during the quarter.  Silver prices have  remained

volatile over this period, and the Trading Advisor has, from time

to   time,  taken  positions  as  market  opportunities  develop.

Demeter  anticipates that gold and silver will remain the primary

metals market exposure for the Partnership.



Soft  Commodities  and Agriculturals - On  March  31,  2000,  the

Partnership  had a reasonable amount of exposure in  the  markets

that  comprise these sectors.  Most of the exposure  was  in  the

coffee,  corn, cotton and livestock markets.  Supply  and  demand

inequalities,  severe weather disruption and market  expectations

affect price movements in these markets.



Energy - On March 31, 2000, 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.   It  is possible  that  volatility  will

remain  high and that significant profits and losses, which  have

been  experienced  in the past, are expected to  continue  to  be

experienced in this market.  Natural gas has exhibited volatility

in  prices resulting from weather patterns and supply and  demand

factors and is expected to continue in this choppy pattern.







<PAGE>

Qualitative Disclosures Regarding Means of Managing Risk Exposure

The Partnership and the Trading Advisor, separately, attempt to

manage   the   risk  of  the  Partnership's  open  positions   in

essentially  the  same  manner in all market  categories  traded.

Demeter  attempts  to manage market exposure by diversifying  the

Partnership's assets among different market sectors  and  trading

approaches, and monitoring the performance of the Trading Advisor

daily.    In    addition,   the   Trading   Advisor   establishes

diversification  guidelines, often set in terms  of  the  maximum

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.   Cash  is  the   only   Partnership

investment directed by Demeter, rather than the Trading Advisor.























<PAGE>

                   PART II.  OTHER INFORMATION



Item 1.  LEGAL PROCEEDINGS

On  March 3, 2000, the plaintiffs in the New York action filed an

appeal of the order dismissing the consolidated complaint.

(Please  refer  to Legal Proceeding previously disclosed  in  the

Partnership's Form 10-K for the year ended December 31, 1999  for

a more detailed discussion).


Item 2. CHANGE IN SECURITIES AND USE OF PROCEEDS

The   Partnership  registered  5,000,000  Units  pursuant  to   a

Registration  Statement on Form S-1, which  became  effective  on

November 10, 1997 (the "Registration Statement") (SEC File Number

333-33975).  The Partnership, Demeter, MSCW and DWR extended  the

offering period for unsold Units until no later than October  16,

1998   pursuant  to  Post  Effective  Amendment  No.  1  to   the

Registration Statement, which became effective on July 10, 1998.



The managing underwriter for the Partnership is DWR.



The  offering  originally commenced on  November  10,  1997  with

4,045,503.483  Units sold through April 1, 1998.   The  aggregate

price  of  the offering amount registered was $50,000,000  (based

upon  the  initial  offering price of $10.00 per  Unit)  for  the

initial  closing  on  January 2, 1998 (the  "Initial  Offering").

After  the  Initial Offering, Units were sold at  three  closings

held

<PAGE>

on  February  2, March 2 and April 1, 1998, at a price  equal  to

100% of the Net Asset Value per Unit at the close of business  on

the last day of the month immediately preceding the closing.  The

aggregate  price  of the Units sold at the four closings  of  the

offering was $40,100,218 (based upon the Net Asset Value per Unit

of  $10.00 at January 2, 1998, $10.13 at February 2, 1998,  $9.53

at   March   2,  1998  and  $9.54  at  April  1,  1998  closings,

respectively).



An additional 149,990.149 Units were sold at subsequent closings;

held  on  August 3, September 1 and October 1, 1998  at  a  price

equal  to  100% of the Net Asset Value per Unit at the  close  of

business  on the last day of the month immediately preceding  the

closing.   Subsequent to these closings, remaining  unsold  Units

were de-registered.



In  conjunction  with becoming part of the Spectrum  Series,  the

Partnership registered an additional 7,000,000 Units pursuant  to

another   Registration  Statement  on  form  S-1,  which   became

effective on March 6, 2000 (SEC File Number 33-90483).



Through  March  31,  2000,  4,206,683.176  total  Units  of   the

Partnership have been sold, leaving 6,988,810.456 Units unsold as

of  March  31,  2000.  The aggregate price of Units sold  through

March 31, 2000 is $41,320,822.95.





<PAGE>

Since  no expenses are chargeable against proceeds, 100%  of  the

proceeds of the offering have been applied to the working capital

of  the  Partnership for use in accordance with  the  "Investment

Program,  Use  of Proceeds and Trading Policies" section  of  the

prospectus  included as part of the above referenced Registration

Statement.



Item 5.   OTHER INFORMATION

Effective  January 31, 2000, Mark J. Hawley resigned as  Chairman

of  the  Board and a Director of Demeter and Dean Witter  Futures

and  Currency  Management, Inc. ("DWFCM") and  Robert  E.  Murray

replaced him as Chairman of the Board of Demeter and DWFCM.




Item 6.   EXIBITS 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.




                            Morgan Stanley Dean Witter Spectrum
                             Commodity Fund L.P.(Registrant)

                            By: Demeter Management Corporation
                               (General Partner)


May 12, 2000                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.