After months of senseless haggling, the Senate, early in the morning of Jan. 1, 2013, by a vote of 89–8, and the House of Representatives, late in the evening of Jan. 1, by a vote of 257–167, passed the American Taxpayer Relief Act of 2012, P.L. 112-240 (the Act). On Jan. 2, President Barack Obama signed the act into law, thereby avoiding the “fiscal cliff.” What was left on the table after the deal, which will set up another prolonged battle that will reinforce the divisiveness that has plagued Congress, are spending cuts, the budget, and the debt ceiling, not to mention basic tax reform.