http://www.americanbar.org/groups/taxation/publications/tax_lawyer_home/ttl-win12-berg.html
This article is pay-walled to members of the American Bar Association but it does seem to have a rather interesting premise. I also note the author appears to pick a fight with IBS Wall of Shame member Bruce Ackermann of Yale University. If anyone gets access to this article it might be something interesting to look it.
