Zeroed-Out 
Three years after the new law took effect, Covey created a pair of $100 million zeroed-out GRATs for Audrey Walton, the former wife of the brother of Wal-Mart Stores Inc. founder Sam Walton. The IRS, which had banned such GRATs through regulation, demanded taxes and took her to court.
In 2000, the U.S. Tax Court found in Walton’s favor, determining the 1990 law didn’t prohibit a “zeroed-out” GRAT. Covey had won a rare prize: an official seal of approval for a tax shelter.
Two years after Covey’s court victory, Adelson set up a GRAT called the “Sheldon G. Adelson 2002 Two Year LVSI Annuity Trust,” Adelson’s SEC filings show. By 2009, he was juggling chunks of his fortune in as many as 10 GRATs at a time, filings show.
Adelson once discussed his approach to inheritance taxes in a legal deposition.
“Listen, the law says you can avoid taxes but you can’t escape taxes,” Adelson testified as part of a 1997 lawsuit over an unrelated business dispute. “We just want to do what is right, but it is prudent and it’s wise to prepare your estate to save taxes.”