A major goal of some tax reform proponents is the elimination of the return filing requirement for many or all Americans. Although the President\u27s Advisory Panel on Federal Tax Reform heard several hours of testimony concerning the possibility of a return-free income tax system, the Report of the Panel failed even to discuss the issue. This Article contends that the Panel was right to recommend (by implication) the retention of a return-based tax system, given the Panel\u27s recommendations for major tax simplification. As long as the return filing obligation is not unduly burdensome which it would not be under the Panel\u27s simplification proposals a filing obligation has significant civic virtues. A return-based system represents an appropriate compromise on the level of visibility and painfulness of taxation, and the filing of an tax return can serve an important ceremonial function as an expression of fiscal citizenship. The civic potential of return filing is not now realized because of the tremendous complexity of the income tax, but that potential could be realized under a simplified system
