lords would pay a tribute (tax) to the Crown in return for protection from
foreign enemies. Smith and Mill recognized the need for another principle of
tax equity for general taxes that were not so clearly tied to particular beneWts
received by the taxpayers.
The remainder of Chapter 11 focuses on the ability-to-pay principle,
indicating how to proceed from the principle to the design of broad-based
taxes. The U.S. federal personal income tax will serve as the primary applica-
tion throughout the chapter. Of all the broad-based taxes, it is the tax most
closely grounded in the ability-to-pay principle.
The Smith±Mill ability-to-pay principle and the Bergson±Samuelson
interpersonal equity conditions of Wrst-best theory are also compared and
contrasted. The older ability-to-pay principle would appear to bear a close
kinship to the newer interpersonal equity conditions. The taxes and transfers
implied by the interpersonal equity conditions surely depend on individuals'
economic well being, that is, on their ability to pay. Even so, the two
principles are not as closely related as one might think. They derive from
fundamentally diVerent views of taxation and, as such, they do not necessar-
ily imply that the government should collect the same tax revenues from
individuals or even use the same taxes.
ABILITY TO PAY: THEORETICAL CONSIDERATIONS
Smith and Mill recognized the limitations of the beneWts-received principle as
public expenditures became more varied and their beneWts more diVused
throughout the population. They reacted by introducing the concept of
taxes as a necessary evil, a sacriWce that individuals have to make for the
common good to support desired public expenditures. Given their perspec-
tive, they saw the fundamental question of tax equity as being one of how the
government should ask people to sacriWce for the commonweal, the common
good. Their answer was that people should be asked to sacriWce in accordance
with their ability to pay. In addition, the pattern of sacriWce should honor the
two principles of horizontal equity and vertical equity. Horizontal equity says
that equals should be treated equally. Two people judged to have equal
ability to pay should bear the same tax burden. Vertical equity allows for
the unequal treatment of unequals; that is, two people with unequal abilities
to pay can properly be asked to bear unequal tax burdens. This new Smith±
Mill ability-to-pay principle was a sacriWce principle, pure and simple. Tax-
payers should not expect a quid pro quo from general or broad-based taxes, in
direct contrast to taxes paid according to beneWts received.
1
Ability-to-pay
1
Adam Smith, The Wealth of Nations, E. Cannan, Ed., G. P. Putnam's Sons, New York,
1904, Vol. II, pp. 300±310. John Stuart Mill, Principles of Political Economy, W. J. Ashley Ed.,
Longmans, Green Co., Ltd., London, 1921, p. 804. For an excellent history of the development
of ability-to-pay principles, see R. A. Musgrave, The Theory of Public Finance, McGraw-Hill,
New York, 1959, chap. 5.
334 ABILITY TO PAY: THEORETICAL CONSIDERATIONS

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