Karen C. Burke (San Diego) & Grayson M.P. McCouch (San Diego) have posted Lipstick, Light Beer, and Backloaded Savings Accounts on SSRN.  Here is the abstract:

The article addresses current proposals for expanding tax-preferred individual savings accounts and their implications for retirement security and tax policy. The authors argue that the yield-exempt approach embraced by the Administration in its proposals is likely to generate enormous long-term revenue losses, exacerbate inequalities in income and wealth, and erode broad-based coverage under employer-sponsored retirement plans. In addition to these fiscal and distributional concerns, they conclude that the proposals pose a serious obstacle to fundamental tax reform.