Christopher H. Hanna (SMU) has published From Gregory to Enron:  The Too Perfect Theory and Tax Law. 24 Va. Tax Rev. 737 (2005).  Here is part of the Introduction:

The Too Perfect Theory has been interpreted to mean that a magic trick may be too perfect, in that not only does it not fool the audience, but the effect itself may lead the audience to discover how the trick is performed…. What is interesting about the Too Perfect Theory is that it seems to be applicable to the law, particularly the practice of transactional law, such as tax law. In other words, is it possible for a transaction to be structured in which the results are too perfect under the tax law?  Most judges, law academics, lawyers, and law students would immediately respond, "Absolutely not."  They would claim that transactional lawyers strive for perfection and anything less may lead to malpractice claims. But, as this Article will show, a transaction may have results that are too perfect under the tax law, and, as a result, the transaction may be subject to recharacterization by the government and the courts.