Abstract
Federal income tax reform is much talked about these days. No longer the sole province of the person with a professional interest in the tax system, tax reform is discussed, at some level or other, by people in every walk of life. This recent popularity is due largely to the widespread unpopularity of the current system. This popularity is also responsible, unfortunately, for making large-scale, reflective, and systemically coherent reform highly unlikely, and for ensuring that frequent, politically motivated, piecemeal legislative change will continue. The Tax Reform Act of 1986 probably illustrates the most to be hoped for in the present climate. 1 Nonetheless, talk of real reform will surely persist, and theoreticians of tax policy will continue to do the hard work that ought to underlie tax reform. Despite the skepticism revealed by the above remarks, this article, too, is a plea for reform. It is not, however, directed at the ills that have stirred public discontent and made tax reform such a popular topic. Instead, it addresses the conceptual features that characterize the federal income tax system as a system. I am interested in changing the way we think about certain fundamental aspects of any income tax system and thereby in clarifying the way we describe, explain, understand, and argue about our own system, whatever it may look like at a particular time. Call this an argument for conceptual reform. Serious normative discussion about our tax system typically falls into one of two broad spheres. The first is ...