San Francisco Chronicle, June 6, 2009 by Marisa Lagos
http://www.sfgate.com/cgi-bin/article.cgi?f=/c/a/2009/06/05/MNJ0180DCU.DTL
UC Berkeley assistant law professor David Gamage said cases such as this one are not as clear cut as both sides would like. “I would say an inquiry like this is very fact intensive,” he said. “The law recognizes that taxpayers have the right to organize their affairs to minimize their taxes, but only within the bounds of what is legal.”