The ubiquitously expressed mouse Surf-i and Surf-2 genes are divergently transcribed, and their heterogenous start sites are separated by up to a maximum of only 73 bp. By using in vitro DNase I, dimethyl sulfate methylation, and gel retardation assays, we have identified five putative promoter control elements between and around the Surf-i and Surf-2 start sites. The effects of each site on the regulation of Surf-i and Surf-2 transcription have been studied in vivo, and four sites were found to be functional promoter elements. A