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A limited number of tax decisions were rendered by the Fifth Circuit during this survey period. Most of these decisions were not noteworthy because they followed previously accepted opinions and rulings. Nevertheless, the Fifth Circuit did render an important opinion in Biedenharn Realty Co. v. United States. This case, involving the dealer-investor problem in regard to real estate sales, is discussed in detail in this tax section, written by Deborah Welch. Following the Biedenharn commentary is a brief survey of other cases decided during the survey period, written by Robert Doty. This survey includes cases dealing with the following topics: trusts, Subchapter S corporations, Miranda warnings to a taxpayer, and gift taxes.