N. Jerold Cohen (Sutherland Asbill & Brennan, Atlanta, GA) has published Too Good to Be True and Too Bad to Be True, 109 Tax Notes 1437 (2005), also available on the Tax Analysts web site as Doc 2005-23498, 2005 TNT 238-26:
In this report, the author questions whether it is fair to impose penalties on taxpayers on the grounds that their tax results were "too good to be true" when the literal language of our code often produces results that many would think were either too good or too bad to be true.
