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1 J. D. Foster, Income and the Art of Tax Distribution Analysis 1 (1997)

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August 1997

Income and the Art of Tax Distribution Analysis

Defining income properly is enormously im-
portant for an income tax, so economists, law-
yers, and accountants have debated the matter
for years. A new dimension of this debate has
opened recently in the area of tax fairness,
thanks to the growing use of tax distribution
tables. These tables seek to portray the distribu-
tion of the tax burden or the tax cut across vari-
ous income percentiles or income levels.
The Joint Tax Committee, which estimates
tax changes for Congress, uses Adjusted Gross
Income (AGI) as its definition for tax distribution
analysis. AGI is relatively well understood, rela-
tively simple, and derives from the income tax it-
self. But AGI is itself a consequence of tax policy
and therefore could be an unsteady basis for
measuring changes in tax policy.
The Treasury Department, on the other
hand, uses Family Economic Income (FED. In us-
ing FEI, Treasury seeks to develop a more com-
prehensive measure of income than AGI. FEI,
for example, includes items of income excluded
from AGI because otherwise the tax code would
become too complex (e.g., imputed rent from
owner-occupied housing), or for other policy
reasons (e.g., the child care credit).
The disadvantage of using FEI is that it is a
highly complex measure of income dependent
on many critical assumptions, each of which
open the calculation to criticism and possible
manipulation. Take, for examplethe inclusion
of the imputed rent from owner-occupied hous-
ing. The idea is that a home owner is both asset
owner and renter. The owner therefore enjoys
both the housing services from his property and
the imputed economic income he would receive
if he rented the house to someone else. To
make such a calculation, Treasury must estimate
what the imputed income would be, which
means estimating what the rent would be. It
must then consider all the expenses that would
be deductible if the owner were landlord, par-

ticularly depreciation and maintenance costs. It
must then discount the imputed net rental
stream going out to the indefinite future to see if
that sum, plus the rental value itself, exceeds the
purchase price of the house.
Given its difficulties and possible disadvan-
tages, why choose FEI over AGI in running distri-
bution tables? Primarily because FEI is useful
when ability-to-pay guides tax policy. If you
believe ability-to-pay is a reasonable guide, then
at the very least you should attempt as compre-
hensive a measure of income as possible - as
Treasury has done in developing FEI.
Ability-to-pay is at the heart of the belief that
taxes should be used to redistribute income from
the rich to the poor (or from producers to non-
producers). But if you do not believe in
redistributionism, you must conclude that ability-
to-pay is not a proper guide to tax policy. There
would be no justification for using the more
complicated FEI in lieu of the more intuitive AGI
as the basis for assessing the tax distribution. Its
use in assessing tax cuts is also dubious. Ability
to pay taxes has little to do with ability to receive
tax cuts. At the very least, the more appropriate
information would be the distribution of the tax
burden after the tax cut has been put into effect
- which, whether the table is done with FEI or
AGI, would continue to show that middle and
upper-income taxpayers are shouldering a dis-
proportionate share of the tax burden.
Tax distribution tables burst on the scene
only a few years ago, thanks to technological
breakthroughs in tax analysis and the rise to
prominence of the fairness debate. Most observ-
ers once took these tables at face value, assuming
they reflected a dispassionate calculation about
which we could all pretty much agree. What
this year's debate has revealed, however, is that
there are a great many assumptions built into
these tables about which there may be little or
no agreement at all.*

By Dr. JD. Foster
Executive Director and
Chief Economist
Tax Foundation

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