Makes sense. My only concern is that it seems that this transfer is making a tax wager that your *marginal* tax rate now will be lower than your *average* tax rate in retirement, when you may very well have less (relative) income and more deductions than you do now.

Although I agree income taxes will probably go up, I have trouble believing they would go up that much. For instance, we now pay marginal (state + fed) income taxes of 34% vs. average taxes of about 20%. Now, this might be a fantastic idea if I leave my job and take a year off, allowing the conversion at a very low tax rate, but it seems dubious at the full rate.