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[[ are simply screwed. Once you make the election to "spread"
the income, that election is irrevocable.

Wouldn't that make it preferable for most people who can't predict their annual
income in the next 3 years to simply convert amounts on a year-to-year basis
according to their income in those years, rather than tieing themselves into a
contract (in effect) to convert a fixed amount per year regardless of how it
impacts them taxwise?]]

Sure...and the less likely you are of your future income, the more sense it makes.

You lose the "time value of money" and the free interest from Uncle Sammy, but you may save tax dollars in the long run.

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