Clever legal arguments win individual cases. They don't change things very much. Change comes when those cases are adopted or, in the the case of GRATs, not immediately shot down by the legislature. It is not the lawyer that initiates the change. He or she provides the option and the larger society either adopts it or not. GRATs (and similar schemes) exist because they are tolerated. Covey's real innovation was in convincing the right people not to move against GRATs, and in gauging the mood of the country at the time. I wouldn't recommend going out on such a limb without appropriate backing. Politics isn;t meant to influence individual cases, but any widespread change beyond the single case is nothing but.