Katarina Olivia Savino (Miller & Chevalier, Washington, D.C.) has published Changing the Calculus: Making Tax Shelters Unprofitable, 58 National Tax Journal 471-82 (Sept. 2005). Here is the abstract:

Tax shelters in the late 1990s gave rise to large tax savings for taxpayers, considerable fees for professionals, and large revenue losses for the government. Discouraging participation in tax shelters requires decreasing the profitability of such participation. This article describes how recent measures deter tax shelters by either decreasing the expected benefits or increasing the expected costs of tax shelters to the various participants. The article also suggests additional measures to further deter tax shelters.