ABSTRACT
Professor Bittker has great difficulty understanding the particular concept of income which is used when the term ‘comprehensive income’ is invoked. Contrary to what Bittker implies, personal income has been used only to estimate the amount of under-reporting of income on tax returns and not as a ‘normative model’ for a comprehensive income tax. The only persons who have referred to personal income as a criterion for defining taxable income are those who oppose the taxation of capital gains in full and reject the whole notion of comprehensive income taxation. Bittker derives great satisfaction from taunting the proponents of comprehensive income taxation for departing from the Haig-Simons definition in one way or another. But he fails to mention that departures from comprehensiveness are permitted by the proponents, and that they have even stipulated the conditions under which departures would be tolerated.
