Terri Guinn (J.D. 2011, San Diego), Casenote, Shareholder to Intermediary: "Thanks…it is 'Appreciated'!" (Starnes v. Commissioner, 680 F.3d 417 (4th Cir. 2012)), 49 San Diego L. Rev. 545 (2012):

Part II of this Casenote explores the history behind the General Utilities doctrine, and Part III explains the why the doctrine was ultimately repealed. Part IV then analyzes Starnes and how it could lead to the resurrection of the General Utilities doctrine through the use of intermediaries. Finally Part V concludes by drawing attention to the ease with which other shareholders, eager to avoid a corporate-level tax, could replicate the Starnes transaction.