The issue of how much to tax the rich and how much to tax the middle-class is a complex one.

Economists, looking at the subject from a strictly financial point of view, use the phrase "vertical equity," meaning the unequal treatment of unequals in determining one's fair share of tax liability. Politicians call it the fairness issue.Many argue that fairness requires a progressive tax structure, where the rich pay proportionately more of their income in taxes than those with lower incomes.

The millionaire surtax may seem to be an easy - and even equitable - way to make the tax system more progressive, but it's also bad tax policy. It's a roundabout way of addressing the shortcomings of the tax code as it currently stands.

Prior to 1987, there were as many as 16 tax brackets and each one had its own marginal tax rate. The Tax Reform Act of 1986, effective in 1988, significantly reduced the number of graduated marginal rates to 15 percent, 28 percent and 33 percent.

In addition, those with the highest incomes pay a flat rate of 28 percent on all their income - from the first dollar to the last. Support for a millionaire's surtax is tantamount to arguing that the flat rate of 28 percent at the upper end of income is not high enough.

A distinct difference in ability to pay taxes exists for couples earning $30,000, $300,000 and $1 million. Yet a married couple filing a joint return is hit with the 28 percent bite once their earnings reach $32,451.

It's obvious that greater progressivity is warranted. But the Democratic surtax proposal is not the best method for achieving this change.

For starters, why should we impose the tax only on those earning $1 million or more. What is so magical about $1 million? Should relatively wealthy individuals with incomes slightly less than $1 million be taxed at the same marginal rate as middle-class individuals?

A more honest, although perhaps politically more difficult, approach is to modify the current graduated marginal rate structure to include a few more rates at the upper-income range.

Perhaps tax reform was taken too far when the number of marginal rates was reduced to three. Creating more tax brackets between the $200,000 and $1 million income range would make it easier to fine-tune the tax system and make it more progressive.

This direct approach is also far easier for taxpayers to understand than the current method of gradually eliminating itemized deductions and personal exemptions, which are recent and confusing changes to the tax code.

Some have argued that in addition to imposing a surtax on millionaires, their income tax records should be made public. Grave questions relative to invasion of privacy, ethics and security are raised by these arguments while only a weak case is made for such disclosure.

Moreover, the distinction of earning $1 million, as opposed to $2 million, or $200,000 seems arbitrary at best.

Would the income level for public disclosure be raised annually to reflect the erosion of purchasing power through inflation? Would the income level for disclosure fall if we experience deflation?

In any case, the 102nd Congress has a difficult task ahead addressing the fairness aspects of the federal income tax. Let's not make its task impossible by adding further issues to the debate.

(Sandra J. Odorzynski is associate professor of economics at St. Norbert College in De Pere, Wis.)