>>Using this technique you would not be able to close form1 without first closing form2.
>
>Somehow this never caused me problems. Wouldn't closing Form1 make the reference to Form2 go out of scope, thus closing it? (If using the LINKED keyword, at least - or creating the form from a class, with a CREATEOBJECT().)

I think the form now holds the reference to another form, so when you close it, it will be a dangling reference.

Check FAQ #7975