Jeffrey C. Glickman & Clark R. Calhoun (both of Alston & Bird, Atlanta have published  The "States" of the Federal Common Law Tax Doctrines, 61 Tax Law. 1181 (2008).  Here is part of the Introduction:

This Article focuses on states’ attempts to apply the federal anti-avoidance doctrines to state tax transactions. Since 2000, there has been considerably more activity in this area at the federal level; thus, it should not be surprising that states have similarly become more aggressive in their attempts to apply these doctrines to undo the state tax benefits of business transactions. …  Peter Faber, a partner with McDermott Will & Emery, predicted an increased use of these doctrines at the state and local tax level. …

There is no question that, in the last several years, states have aggressively attempted to eliminate a taxpayer’s ability to minimize or to eliminate its state tax burden in ways viewed by the states as frustrating the intent of their tax statutes, including applying these federal common law tax doctrines to various types of business transactions. As one might suspect, this has become another area where states have created inconsistencies among themselves. Not surprisingly, individual states have been guilty of inconsistent application within their own jurisprudence.

The goal of this Article is to provide tax professionals with a better understanding of the application of these federal tax doctrines at the state level. Part II provides a brief overview of the doctrines at the federal level. Part III.A summarizes recent congressional attempts to codify the economic substance doctrine and several successful efforts by states to address these doctrines in their statutes and regulations. Part III.B examines state administrative guidance and judicial opinions with regard to these doctrines in the corporate income tax, transaction tax (that is, sales-use and real estate transfer taxes), and property tax areas. Particular emphasis is given to the context in which the doctrines were and were not applied. Finally, Part IV provides some concluding thoughts for professionals who regularly find themselves providing transactional tax advice or who are called upon to issue legal opinions (whether or not for purposes of satisfying the financial reporting requirements for income tax reserves pursuant to FASB Interpretation or other financial accounting purposes) on the ability of a taxpayer to achieve a desired state tax result from a particular business transaction.