Upside-down Deduction

Over the recent years, several proposals were made to enhance database systems with automated reasoning. In this article we analyze two such enhancements based on meta-interpretation. We consider on the one hand the theorem prover Satchmo, on the other hand the Alexander and Magic Set methods. Although they achieve different goals and are based on distinct reasoning paradigms, Satchmo and the Alexander or Magic Set methods can be similarly described by upside-down meta-interpreters, i.e., meta-interpreters implementing one reasoning principle in terms of the other. Upside-down meta-interpretation gives rise to simple and efficient implementations, but has not been investigated in the past. This article is devoted to studying this technique. We show that it permits one to inherit a search strategy from an inference engine, instead of implementing it, and to combine bottom-up and top-down reasoning. These properties yield an explanation for the efficiency of Satchmo and a justification for the unconventional approach to top-down reasoning of the Alexander and Magic Set methods

Giving Credit Where Credits Are (Arguably) Due: A Half Century\u27s Evolution in the Design of Personal Tax Expenditures

In the late 1960s, when Stanley Surrey introduced the concept of tax expenditures and the federal government began producing tax expenditure budgets, personal tax expenditures in the form of deductions (for nonbusiness interest, charitable donations, state and local taxes, and medical expenses) equaled roughly 1.2% of gross domestic product, and personal tax expenditures in the form of credits were virtually nonexistent. Although Surrey was critical of all tax expenditures, he had particular scorn for tax expenditures in the form of deductions, which he characterized as upside-down subsidies. He explained that converting deduction tax expenditures to credits would make them less objectionable, by eliminating their upside-down character. Over the ensuing half century, Congress has shifted from deductions to credits—gradually for decades, with a dramatic acceleration of the shift in 2017. Today, in sharpest contrast with the Surrey era, major tax expenditures in the form of personal credits equal roughly 1.23% of GDP, while major deduction expenditures have fallen to about 0.61%. This Article describes this fundamental transformation of a significant fraction of the national economy, first from a big picture perspective and then with detailed accounts of the evolution of the major personal tax expenditures. The Article also offers a policy analysis of the transformation, with three major conclusions: (1) Congress has been overly influenced by Surrey’s upside-down critique, in that it has wrongly viewed as upside-down subsidies deductions justified on income-defining (ability-to-pay) grounds; (2) in designing personal tax expenditures, Congress has legislated as if a number of design features automatically follow from the choice between deduction and credit, when in fact they do not; and (3) Congress has been right (at least mostly) to ignore Surrey’s recommendation that all credits should be taxable

Pease Provision in Fiscal Cliff Deal Doesn't Discourage Charitable Giving and Leaves Room for More Tax Expenditure Reform

The recent "fiscal cliff" deal reinstated a limit on itemized deductions for high-income taxpayers known as the "Pease" provision, which policymakers created as part of the 1990 bipartisan deficit-reduction package but which the Bush tax cuts phased out between 2006 and 2010. In recent days, some pundits and leaders of some charitable organizations have suggested that because Pease limits the total amount of itemized deductions that high-income filers can claim, it will reduce the incentive for taxpayers to donate to charity. That suggestion is incorrect, however, as a close look at Pease makes clear

Budgeting for Growth and Prosperity: A Long-Term Plan to Balance the Budget, Grow the Economy, and Strengthen the Middle Class

Proposes reducing the deficit by investing in education, infrastructure, and technology; spending more efficiently; bolstering the social safety net; containing healthcare costs; simplifying the tax code; and raising gas and financial transaction taxes

Of Head Taxes, Income Taxes, and Distributive Justice in American Health Care

Havighurst and Richman have made an important contribution by uncovering ways in which the current system of health care financing, including the income-tax treatment of employer-provided health insurance, has disturbing distributional effects

Query Evaluation in Deductive Databases

It is desirable to answer queries posed to deductive databases by computing fixpoints because such computations are directly amenable to set-oriented fact processing. However, the classical fixpoint procedures based on bottom-up processing — the naive and semi-naive methods — are rather primitive and often inefficient. In this article, we rely on bottom-up meta-interpretation for formalizing a new fixpoint procedure that performs a different kind of reasoning: We specify a top-down query answering method, which we call the Backward Fixpoint Procedure. Then, we reconsider query evaluation methods for recursive databases. First, we show that the methods based on rewriting on the one hand, and the methods based on resolution on the other hand, implement the Backward Fixpoint Procedure. Second, we interpret the rewritings of the Alexander and Magic Set methods as specializations of the Backward Fixpoint Procedure. Finally, we argue that such a rewriting is also needed in a database context for implementing efficiently the resolution-based methods. Thus, the methods based on rewriting and the methods based on resolution implement the same top-down evaluation of the original database rules by means of auxiliary rules processed bottom-up

Rhetoric and Reality in the Tax Law of Charity

This Article contrasts the rhetoric of public benefit connected to charity in the law with the reality of private control of charitable organizations. It argues that the tension between the rhetoric and reality have produced norms of entitlement that undermine taxation. It offers an approach to the role of charity under the law by defining the obligations of government in a just society, qualifying the economic framework dominant in the literature concerning charities, and identifying what private charity can achieve that governments cannot. This Article concludes by endorsing the charitable deduction in the tax law on terms consistent with this revised approach