meet either— (I) the income test of paragraph (2) in effect for such preceding taxable year, or (II) the asset test of paragraph (3) in effect for such preceding taxable year, except that each such paragraph shall be applied for purposes of this clause by substituting an amount equal to one-half of the dollar amount otherwise in effect for such taxpayer under such paragraph for each such preceding taxable year for such dollar amount, and (ii) the taxpayer elects, in such manner and form and at such time as the Secretary may prescribe, not to be so treated for such first taxable year. (B) Earlier termination election of applicable taxpayer status for divorced individuals If— (i) an applicable taxpayer ceases to be a married individual by reason of a decree of divorce or separate maintenance issued during any taxable year, and (ii) such taxpayer, for the first taxable year following the taxable year described in clause (i), does not meet either— (I) the income test of paragraph (2), except that such paragraph shall be applied for purposes of this subclause by substituting $1,000,000 for the dollar amount otherwise in effect for such taxpayer under such paragraph, or (II) the asset test of paragraph (3), except that such paragraph shall be applied for purposes of this subclause by substituting $10,000,000 for the dollar amount otherwise in effect for such taxpayer under such paragraph, then such taxpayer may elect, in such manner and form and at such time as the Secretary may prescribe, not to be treated as an applicable taxpayer beginning with such first taxable year. (C) Election An election under subparagraph (A) or (B)— (i) shall be made with the taxpayer's return of tax for the taxable year to which such election first applies (or such other time as the Secretary shall prescribe) and shall be in such form and manner as the Secretary may prescribe, and (ii) shall apply to such first taxable year and all subsequent taxable years until the first taxable year for which the taxpayer is again treated as an