Timothy R. Hicks (J.D. 2008, Cumberland) has published Comment, Government Victories Using the Economic Substance Doctrine: A Changing of the Tide in Tax Practice? 38 Cumb. L. Rev. 101 (2008).  Here is the Conclusion:

In America, as perhaps nowhere else, businesses and taxing authorities play the “tax shelter game” with unrivaled dedication. From time to time, the IRS launches a full on attack using a host of judicially sanctioned weapons. In light of such an onslaught, the tax shelter industry retreats only to return with innovative and intricate ways to minimize their corporate tax bills. Without question, the government is currently on the attack using the economic substance doctrine as its main artillery, but the true impact of the government’s recent appellate successes is not yet known. However, as if the Service had any doubts, the tax shelter game will not end with this line of government victories; it will continue as long as there are tax savings to be had and tax practitioners with creative solutions to paying corporate tax.