Ruling Level Max

Yessah! :) That's how I've seen it played, at least. I'm sure a more learned member will correct me if I'm wrong (and I apologize if that is the case!)
 
Yes, you can level up a Benched Pokemon if you flip heads. That's the whole point behind Level Max; level up without having to head to the Active spot (Heatran in particular appreciates this card very much).

Of course, if you want to level up your Active Pokemon if you get heads, that's fine, too.
 
Keep in mind that poke-powers like Gallade 4 X's will not activate if you level up with level max because the power says it needs to be leveled up from your hand onto your active pokemon.
 
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