Posted: Apr 25, 2005 By: ROBERT HOLDEN

Comment: To: The President's Advisory Panel on Federal Tax Reform <
">comments@taxreformpanel.gov >



Suggestions on the Tax Reform Principles, Process and on the reform, itself:



1. Definition of the Problem. Before you recommend solutions, make
sure that you have adequately defined the problem you are trying to solve in
a formal document. Without such a document, everyone will have a different
perception of what the problem is, and will focus on his or her pet peeves
while ignoring the rest.
2. Prioritize the list of Problems. Prospective solutions will attack
some problems, but aggravate others.
3. Create a yardstick from the Prioritized List of Problems to sort
through suggested solutions, perhaps in the form of a checklist along with a
statement of principles.
4. One principle to consider is that no individual making more than the
median income should pay less than one who is at the median income level.
The public perception is that the more affluent individuals pay less than
their fair share or escape paying income taxes entirely. VAT has the
potential to tax everyone at the same rate. Any progressive rate solution
should do at least as well as VAT, while eliminating loopholes.
5. Write a system level specification for the most attractive
solutions. NASA and the military have used the systems engineering
discipline to create design documents to develop everything from Lunar
Landers to Satellite Navigation Systems to entire National Defense Systems.
The specification in this case would provide a template for incorporating or
discarding features of suggestions.
6. Feature the Specification in your report to the President as part of
the formal definition of your recommendation.
7. Revise the specification over time to provide the framework for
making changes to the laws and regulations necessary for keeping Tax Reform
up to date.
8. In considering multi-tiered tax brackets, develop mathematical
models to determine where the break points ought to be, rather than just
picking a number out of a hat. This makes the choice of break points more
transparent and maintainable over time. One such model might define the
break points at multiples of the standard deviation from the median income.

9. Once this process is established, evaluate promising suggestions
against the templates you have established, so the authors of suggestions,
the general public, the government and the President can identify why you
recommend adopting some solutions and reject others.
10. Consider recommending a body, such as your panel, to perpetually
monitor tax reform, updating the definition of the problem, guiding
principles, yardsticks, etc. and report annually to the President or to
Congress.

Good luck and God speed.



Robert R. Holden

1310 Pearl Street

Santa Monica, CA 90405-2606

(310) 452-5902

holden_rr@hotmail.com