With regard to the two year deferral and the election to opt out, my understanding is that married taxpayers filing a joint 2010 tax return can take different approaches pursuant to IRC Sec. 408A(d)(3)(A)(iii). Do I have this right?

If so, then married taxpayers who are both converting can effectively spread the income recognition related to 2010 conversions over 3 years, potentially maximizing AMT marginal rates where applicable.