Burgess J.W. Raby & William L. Raby have published Bootstrap Sale to Key People Survives Attack, also available on the Tax Analysts web site as Doc 2005-12991, 2005 TNT 115-32:

In Getting Shareholder Loans Off the Books, Tax Notes, June 25, 2001, p. 2197, we quoted the opinion by Senior Tax Court Judge Arthur L. Nims, III, in Combrink v. Commissioner, 116 T.C. No. 24 (2001), that "whatever particular abuses may have led to the enactment of § 304, we may not judicially create a supposed policy-based exception where a transaction falls within the plain language of the statute as written." The taxpayers in Combrink thus were held to be in receipt of ordinary dividend income when one corporation they controlled used its interest in another to pay a debt it owed the other.  The problem for tax practitioners, however, is that the plain language of § 304 is seldom so plain that something falls neatly within it. In fact, the content of § 304 was described as a "rococo fugue of tax law" by the Tax Court in a recent case involving a Michigan businessman named Richard Hurst. However, § 304 was not the biggest tax problem that faced Mr. Hurst when he sold the family business in 1997.