Thanks to those that have responded to my question. The IRS also told me that you get to determine how much of your EFI you put on line 2 of Schedule J, as long as it's not more than the total on Line 1. The remainder of Line 1, if any, would be taxed at the 2007 rates. So your still paying tax on all the taxable income. The amount you elect to put on Line 2 would then be taxed averaging the amounts for previous years, which if those previous years had lower income, could result in paying less tax overall.