IN A well-known series of papers Franco Modigliani and Merton Miller^ have out- lined a general framework for the analysis of the effects of capital structure and divi- dend policies on the valuation of the corpo- ration under uncertainty. What disagree- ment remains about their conclusions stems mainly from different beliefs about the effects of various market imperfections on their analysis.- Modigliani and Miller them- selves have dealt comprehensively with one such imperfection, namely the tax system as it affects corporations directly.^ However, while they have directed attention to the effects of the tax system as it relates to the taxation of corporate income, their papers are characterized by an ailmost total neglec; of the complementary aspect of the system, which is the taxation of individuals. It is the purpose of this paper to extend their analysis to incorporate the effects of those features of the personal tax structure which are relevant for the valuation of the corpo- ration. Two features of the personal tax struc- ture stand out in importance for the theor}' of valuation. First is the provision of the existing tax code which permits individuals as well as corporations to deduct interest