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This paper establishes that, far from being able to derive the principle of horizontal equity from utilitarianism, the principle is actually inconsistent with utilitarianism in a variety of circumstances.We derive conditions under which (a) it is optimal to impose random tax schedules (ex post randomization); and (b) it is optimal to randomize the tax schedules imposed on a set of otherwise identical individuals (ex ante randomization).The implications for optimal tax theory are discussed.More generally, it is shown that there are a number of potentially important economic situations with which the principle of horizontal equity may be inconsistent not only with utilitarianism but even with Pareto optimality.
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