Personal deductions have an enormous impact on the revenues raised by the federal income tax. The medical deduction and the exclusion of employer-provided health insurance alone are estimated to reduce tax revenues by nearly thirty billion dollars annually. 1Additional billions of dollars of potential tax receipts are lost by allowing deductions for charitable contributions, nonbusiness state and local taxes, and interest on owner-occupied dwellings. 2 It is not surprising, then, that personal deductions have been a popular subject of tax scholarship. Though much of the tax literature in this area focuses on the merits of particular code provisions, some scholars have offered more general theories of the appropriate role of personal deductions in an income tax. Three of these theories are particularly important.
The tax expenditure model advocated by the late Stanley Surrey is, perhaps, the most prominent theory. 3 The tax expenditure model treats personal deductions and other departures from the Surrey-defined "normal" tax base -- a variant of net income -- as equivalent to direct government expenditures. 4 Surrey argues that these tax expenditures should be evaluated by the same standards as direct government outlays. 5 Applying these standards, Surrey concludes that most tax expenditures are undesirable because they provide fewer benefits to the poor than to the rich, who are subject to higher marginal rates and thus are better able to use the deductions. 6
A second theory of personal deductions is offered by Professor William Andrews. 7 Like the tax expenditure ...