Yoram Keinan (Ernst & Young) has published Rethinking the Role of the Judicial Step Transaction Principle and a Proposal for Codification, 22 Akron Tax J. 45 (2007).  Here is part of the Introduction:

This article will continue as follows. The first part discusses the fundamentals of the general principle of substance-over-form from which the step transaction doctrine (as well as other common law anti-abuse rules) has emerged. The second part sets forth the building blocks of the step transaction doctrine and its application in practice. Part III elaborates on the three alternative threshold tests that courts have developed over the years pertaining to the step transaction doctrine. Part IV discusses another important element in determining whether the doctrine should apply to a given transaction-the lapse of time between each step. The fifth part discusses the main controversial element of the step transaction doctrine, which is whether the IRS can prevail in a step transaction case where each step in the disputed transaction has economic substance and business purpose. Three recent cases in which the step transaction doctrine was only used by the IRS as an alternative weapon are discussed in Part VI to emphasize my point that the doctrine’s role has diminished over the years. Part VII sets forth a proposal to codify the step transaction doctrine in accordance with existing case law. Finally, Part VII contains my conclusions.