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66 Taxes 91 (1988)
Perception, Reality and Strategy: The New Alternative Minimum Tax

handle is hein.journals/taxtm66 and id is 91 raw text is: Perception, Reality and Strategy:
The New Alternative Minimum Tax

The author examines the reasons for the
minimum tax in the context of political as well
as more directly substantive effects: as a
means of creating the public perception that
the income tax system is fair and as a way of
increasing progressivity (and lessening
regressivity) while reducing the overall use of

Daniel Shaviro is an assistant
professor at the University of
Chicago Law School.
@ 1988, Daniel Shaziro

I. Introduction
A. The Federal Tax System: Reflections
of a Long-Standing Ambivalence. The federal
income tax system has long reflected congres-
sional and public ambivalence about its goals.
On the one hand, it levies a tax upon income.
That is, it raises revenues for the federal govern-
ment in relation to an economic measurement
of consumption and accretions to wealth.1 In
* The author is grateful to the Russell Baker Schol-
arship Fund for financial support, and to Walter Blum,
Marvin Chirelstein, Richard Epstein, and Stephen Utz,
for reading and commenting on earlier drafts. Any er-
rors are solely the author's responsibility.
1Income has been defined as the algebraic sum
of (1) the market value of rights exercised in consump-
tion and (2) the change in value of the store of property
rights between the beginning and the end of the period
in question. Simons, Personal Income Taxation 50 (1938).
A broader definition of income as a flow of psychological
satisfactions, while intellectually sounder, generally is
viewed (with good reason) as unadministrable. See, e. g.,
Marsh, The Taxation of Imputed Income, 58 Political
Science Quarterly 514, 519 (1943); Warren, Would a
Consumption Tax Be Fairer Than an Income Tax?,
89 Yale Law Journal 1081, 1095-97 (1980). Perhaps more
important than these administrative concerns, in the
context of this article, is that the notion of economic
income, however incoherent and unmeasurable when
generalized to the level of valuing psychic satisfactions,
works well when confined to more limited questions for
Which standards of economic measurement exist. See
Bittker, A 'Comprehensive Tax Base' as a Goal of In-
come Tax Reform, 80 Harvard Law Review 925 (1967)
(Continued on following page.)

TAXES-The Tax Magazine


February, 1988 e Vol. 66 No. 2

February, 1988

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