Vanderbilt Law Review


William F. Fox

First Page



This Article evaluates the pros and cons of a state individual income tax from the perspective of an economist. The Article examines the income tax as one component of a tax structure that is best suited for raising a given level of revenues. The important assumption in the analysis is that the level of state public expenditures is determined by residents' demand for public services. This assumption does not preclude the tax structure from allowing greater or lesser expenditures than are demanded during any single year; rather, the assumption is that over time tax levels provide revenues that are in accord with consumer preferences for public services.

There are two basic implications to this assumption. First, it is unnecessary to consider how the revenues will be spent to determine whether an income tax is a desirable revenue generator. Second, based on this assumption, an income tax (or any tax) is most effectively evaluated relative to another tax because the existence of an income tax will result in either a direct replacement of or a decrease in another tax. All taxes are politically and economically disadvantageous when analyzed by themselves, so each tax is best judged relative to other taxes. At the state level, the income tax is best evaluated relative to the sales tax. Thus, the analysis below is frequently a comparison between the characteristics of an income and a sales tax. There are other taxes that could be compared with the income tax, but these levies generally would be limited revenue generators in comparison to sales and income taxes.

Part II of this Article is a brief overview of the current practice in state income taxation. Part III considers the pros and cons of using an income tax as a revenue generator, including analysis of the tax's potential as a revenue generator, the economic effects of the tax, the equity implications raised by the tax, and the administrative concerns in using the tax. Part IV draws together these pros and cons to reach a conclusion.