what i usually do is put the <form> tags in the same spot. What i mean by this is if i put tags before the <td> then i put it after the closing of the </td>. look at this sample table below. i have added three different forms in this table to show you where i would put them. just make sure that if you use where i placed the orange one, use the same color for the closing..
<form>
<TABLE border="0" cellPadding="0" cellSpacing="0" width="425">
<TBODY>
<form>
<TR>
<form>
<TD align="left" bgColor="#333399" height="23" vAlign="top" width="13">
<form>
TEXT HERE
</form>
</TD>
</form>
</TR>
</form>
</TBODY>
</TABLE>
</form>
for as long as i have done this.... i have not had any problems
Brad