way of creating a Roth IRA account though. Conversion is not subject to income restrictions.
The way I understand why the IRS leaves an open door is that the IRS needs imminent cash flow right now. The IRS created in 2010 such a mechanism to encourage wealthy individuals to roll over from traditional IRAs to Roth IRAs. Assuming many people opt to do so, the IRS can levy taxes right now on capital gains realized in the traditional IRA accounts which are to be rolled over to the Roth IRA accounts.
In your case, you don't have to pay any tax upon conversion because you have not yet made profits in your traditional IRA account.