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60 Tax L. Rev. 1 (2006-2007)
The Three Goals of Taxation

handle is hein.journals/taxlr60 and id is 9 raw text is: The Three Goals of Taxation
REUVEN S. AVI-YONAH*
I. INTRODUCTION
The current debate in the United States about whether the income
tax should be replaced with a consumption tax has been waged on the
traditional grounds for evaluating tax policy: efficiency, equity, and
administrability. For example, Joseph Bankman and David Weisbach
recently argued for the superiority of an ideal consumption tax over
an ideal income tax on three grounds: First, that the consumption tax
is more efficient because it does not discriminate between current and
future consumption,' while both income and consumption taxes have
identical effect on work effort. Second, that the consumption tax is at
least as good at redistribution as the income tax, and thus can equally
satisfy vertical equity.2 Third, that the consumption tax is easier to
administer than the income tax because it makes no attempt to tax
income from capital and thus can omit many of the vexing complica-
tions that arise from such an attempt, like accounting for basis.3
One can agree or disagree with Bankman and Weisbach, and this
debate will no doubt go on.4 For the sake of the argument, however,
* Irwin I. Cohn Professor of Law, the University of Michigan. I would like to thank
Richard Ainsworth, Anne Alstott, Bill Andrews, Steve Bank, Michael Barr, Richard Bird,
David Duff, Yosef Edrey, Michael Graetz, Dan Halperin, David Hasen, Jim Hines, Louis
Kaplow, Robert Kuttner, Kyle Logue, Yoram Margaliyot, Alex Raskolnikov, Jim Repetti,
Diane Ring, Julie Roin, David Schizer, Dan Shaviro, Reed Shuldiner, Joel Slemrod, Jeff
Strnad, Dennis Ventry, David Weisbach, and participants in the 2005 Harvard Seminar on
Current Research in Taxation and in workshops at the University of Toronto and Tel Aviv
University for their helpful comments.
1 Joseph Bankman & David A. Weisbach, The Superiority of an Ideal Consumption Tax
over an Ideal Income Tax, 58 Stan. L. Rev. 1413, 1423, 1425 (2006).
2 Id. at 1428-30.
3 Id. at 1418.
4 Part II addresses the argument in regard to redistribution. In regard to efficiency,
Bankman and Weisbach rely on a 1976 paper by Atkinson and Stiglitz to argue that it is
incorrect to claim that there is a trade-off between reducing the disincentive to save by
adopting a consumption tax, and reducing the incentive to work by increasing taxes on
wages (to replace revenue lost as a result of exempting income from savings). Id. at 1414,
1420, 1422-28; A.B. Atkinson & J.E. Stiglitz, The Design of Tax Structure: Direct Versus
Indirect Taxation, 6 J. Pub. Econ. 55 (1976). For an example of the argument for the trade-
off theory, see Jane Gravelle, The Economic Effects of Taxing Capital Income 11-50
(1994). Bankman and Weisbach argue that the trade-off theory is untrue because the tax
on income from savings also reduces work effort. Bankman & Weisbach, note 1, at 1422.
But it is quite plausible to assume that people systematically value future taxes less than
current taxes by more than the time value of money, and, if so, the current tax on wages
1

Imaged with the Permission of N.Y.U. Tax Law Review

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