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Three years ago, when former California Gov. Jerry Brown made his proposal for a flat tax the keystone of his campaign for president, the idea fell - well - flat.

Bill Clinton mocked it as a sop to the rich that would wreck Social Security and inflict a crushing blow to the poor. In New York, where Brown finished third in the Democratic primary behind Clinton and Paul Tsongas, voters who were interviewed after they left their polling places were decidedly unenthusiastic about Brown's tax plan.Now, in yet another indication of how the political winds in the country have shifted, several candidates for the 1996 Republican presidential nomination and some of the top Republican leaders in Congress are advocating replacing the graduated income tax with a flat tax.

People who spent the weekend struggling to meet Monday's deadline for filing 1994 income tax returns should not get their hopes up. There is almost no chance that the current tax system, with all its forms and tax brackets, will be overhauled this year or next. But if a Republican gets elected president next year, the prospects for a flat tax will be much improved.

Even President Clinton, while still not a champion of the idea, is taking a much less strident tone about it than he did during the heady days of the New York primary.

"Anything we can do to simplify the tax code, consistent with fairness and not exploding the deficit, we ought to do," the president told interviewers on CNN last week. "The first time I heard about a flat tax, I thought it sounded like a pretty good idea."

But Clinton went on to say, "Every analysis that I have seen done indicates that the flat tax proposals that are out there now will increase the deficit and increase taxes on all Americans with incomes of under $200,000 a year."

Meantime, Rep. Richard A. Gephardt of Missouri, the House minority leader, who seems to delight in taking positions on economic matters at odds with the president, has said that he is working on, if not a flat tax, then a flatter one than what the nation has now.

The general idea of a flat tax is that instead of taxpayers paying a larger percentage of their income in taxes as their income grows (up to nearly 40 percent of taxable income now for the wealthiest Americans), everyone would pay the same rate. Most, if not all, deductions would be abolished.

Rather than struggling every April with columns of numbers and pages of forms, taxpayers theoretically could simply fill out a postcard with their income on one line, minus personal exemptions for themselves and their dependents on the next line, times the tax rate on the third line and the resulting tax they owed on the fourth.

There is no mystery why the idea has taken root. Almost everyone agrees that the current tax system is wrongheaded.

For companies and self-employed people, the Internal Revenue Code can be frustratingly complicated and frightfully expensive to comply with. The tax law rewards consumption and penalizes saving, exactly the opposite of the nation's economic interest. And in many instances it is patently unfair: to some working married couples, for instance, who pay much more in taxes than do unmarried contemporaries who cohabitate and file separate returns.

But in many respects a flat tax is like universal health insurance, a balanced budget, gun control and mandatory prison sentences. The more the layers of the problem are peeled away, the less attractive the solution becomes. That, politicians find, is often the case with seemingly simple solutions to hideously complicated problems.

As a rule in tax policy, simplicity and fairness are at odds with each other. The simpler a tax system, the more unfair it tends to be. The fairer one is, the more complicated it is likely to be.

Perhaps the biggest political hurdle to a flat tax is that in almost all instances, middle-income taxpayers would owe a little more than they do now in taxes and the wealthy would owe much less.

The chief congressional proponent of a flat tax, Rep. Dick Armey of Texas, the House majority leader, advocates a flat tax rate on wages and pensions of 20 percent for three years, falling to 17 percent thereafter. Interest, dividends and capital gains would be exempt from taxation.

The personal exemption would be $13,100 for each adult and $5,300 for each child, meaning that a couple with two children and income below $36,800 would owe no income taxes. But beyond that, no deductions would be allowed: not for mortgage interest, not for charitable contributions, not for anything.

The Treasury has calculated that Armey's plan would raise nearly $200 billion a year less than the current system, would lower the taxes of people with incomes above $200,000 a year by more than 25 percent and would raise almost everyone else's taxes.

Armey does not take serious issue with the Treasury's estimate of the revenue loss. Part of the appeal of his plan, he says, is that Americans would get a tax cut. He expects Congress to find offsetting spending reductions to keep the deficit from growing.

As for the rich getting a windfall, Armey and his allies say the problem is overestimated. Affluent people, they believe, would earn so much more by putting to productive use what they would otherwise pay to the government that they might even end up paying more in total taxes.

If that does not sound like a persuasive argument, try this one: Americans spend tens of billions of dollars a year - hundreds of billions, by some estimates - keeping records, hiring accountants, paying revenue agents and otherwise complying with the current tax system. What if all that money could be saved? Even if it all went into the pockets of wealthy Americans, they would invest it in ways that would put others to work, and everyone would be better off.