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Survey Article


The Court of Appeals for the Eleventh Circuit during 1997 rendered fewer reported decisions dealing with federal tax issues than in prior years. Nevertheless, in one of the biggest developments in cooperative taxation, the Eleventh Circuit decided Gold Kist Inc. v. Commissioner, which involved the interpretation of the tax benefit rule as set forth in the 1983 Supreme Court decisions in Hillsboro National Bank v. Commissioner and United States v. Bliss Dairy, Inc. Other decisions involved the qualification of corporations as "farm-related taxpayers," employment taxes, federal tax liens, issues on appeal, litigation costs, and a bankruptcy tax issue.