A flat rate comprehensive federal income tax could be achieved by replacing graduated rates with a single rate that applies to all taxpayers, eliminating many currently available deductions and credits, and treating as taxable income types of economic gain presently excluded from the tax base. The fact that Congress is seriously considering such radical changes makes it appropriate for tax scholars to reconsider longheld beliefs about the ideal structure of an income tax. This article analyzes the characteristics and underlying rationale of a progressive flat rate comprehensive income tax and reconsiders the nature and purpose of a progressive income tax. Part I of this article describes how adopting a flat rate comprehensive income tax that uses a personal exemption could result in tax burdens substantially more progressive than occur under the current system. Part II explores the nature of individual entitlement to income in our post-liberal society and the purpose of the income tax. In addition, Part II presents an argument for a personal exemption equal in amount to the minimum wage. Part III examines the proper role of shared living arrangements in determining tax liability and concludes that a flat rate comprehensive income tax, properly designed and understood, produces appropriate tax burdens for both married and unmarried individuals. Part IV develops a case for integration of the income tax and the social security system, which builds on the argument for linking the personal exemption to the minimum wage.
Tax Policy for Post-Liberal Society: A Flat Tax Inspired Redefinition of the Purpose and Ideal Structure of a Progressive Income Tax, 58 S. CAL. L. REV. 727