The strategies work. They also require Tier-04 clients to hold them.
Baszucki — Roblox. The Roblox founder multiplied his § 1202 exclusion at least twelve times across his wife, four children, mother-in-law, and even a first cousin-in-law, with his mother-in-law then gifting her own QSBS shares to additional relatives in fall 2020. The pattern was reported by The New York Times and ProPublica in December 2021. The technique is structurally recognized under I.R.C. § 1202(h), which provides for carryover treatment on QSBS gifts; practitioner consensus is that properly-structured multi-trust stacking is permitted, but that consensus assumes the structural discipline this resource exists to enforce.
Huang — Nvidia. Different vehicle, same tier. The Huangs transferred 584,000 Nvidia shares into an IDGT in 2012 (then ~$7M) and 3M+ shares into GRATs in 2016 (then ~$100M). Today those positions are worth $15B+, with an estimated $8B in estate tax savings. Nvidia was already too large for §1202 at transfer time, so the play was GRATs and IDGTs rather than QSBS stacking — but the underlying lesson is identical: the freeze techniques work, at scale, when the client and the documentation are matched to the strategy.
Walton. Audrey Walton — the Walmart heir — established Walton GRATs as permissible under §2702 by litigating the IRS through Tax Court. She won. Mrs. Walton was a Tier-04 client by definition; the position required it.
The pattern across all three: aggressive in the right tier is sophistication. Aggressive in the wrong tier is malpractice. The taxpayers who lost in the published cases — Hoensheid, Ju, Leto, the FLP retained-control line — weren't outmatched on the law. They were outmatched on documentation, discipline, or capacity to litigate. That is what Tier really measures.