Shifting the budget debate from whether to raise taxes to whose taxes to raise puts Democrats on equal political footing with Republicans in deficit-reduction talks between the White House and Congress, political analysts said yesterday.

"We're on stronger ground arguing 'which' rather than 'whether,' " said Democratic pollster Harrison Hickman.

Instead of harping on the need to raise taxes, Democrats now have a chance to argue fairness and equity for their traditional constituencies, working- and middle-class Americans. "That has traditionally been an argument Democrats have been able to use," said Carter Eskew, a Democratic consultant.

Democrats argue that the economic policies of the last decade have benefited the wealthy at the expense of the middle class. Since 1980, for instance, the effective federal tax rate dropped 14.1 percent for the wealthiest taxpayers while rising 4 percent for the middle fifth, according to a House Ways and Means Committee analysis.

Meanwhile, more than half of the inflation-adjusted rise in total family income in 1978 and 1988 went to the richest 5 percent, according to Commerce Department data.

"We are undertaxing the wealthy," said Alice Rivlin, senior fellow at the Brookings Institution.

Citizens for Tax Justice, a liberal group, estimates that if the tax code were as progressive as it was in 1977, the richest one million families would pay an effective rate of 43 percent instead of 27.9 percent and the Treasury would collect an additional $84 billion.

Robert S. McIntyre, the group's director, advocates raising the top corporate and individual rates, tightening inheritance taxes, eliminating the accelerated depreciation deduction and ending deductions for interest paid on debt used in leveraged buyouts.

Last week, 134 House Democrats wrote House Speaker Thomas S. Foley (D-Wash.) arguing that any new taxes "must be levied against those who have gotten the biggest tax cuts in recent years and have enjoyed the lion's share of income growth -- those at the very high end of the income scale."

But that may be easier said than done. "It's a wonderful rhetorical slogan, but when it comes down to real deficit-cutting there's just not enough wealthy people to tax," said William Schneider of American Enterprise Institute.

Raising the top personal income tax bracket to 33 percent to eliminate the so-called bubble under which the highest earners are taxed at a lower rate than upper-middle income people would only raise $3.8 billion in revenue in the first year and $41.9 billion over five years, according to the Congressional Budget Office.

Budget negotiators have set themselves a deficit-reduction target of about $50 billion for fiscal 1991.

In order to raise enough, lawmakers are likely to tailor a package of tax increases that would spread the burden, much as New Jersey Democratic Gov. Jim Florio has done.

Florio doubled income taxes for families earning more than $150,000. But he also raised the sales tax and extended it to such items as soap and toilet paper.

Democrats are divided over excise taxes. Some favor a combination of taxes on cigarettes and alcohol, gasoline and imported oil. Others say excise taxes would hit the poor and middle-class hardest.

Democrats oppose Bush's call to lower the tax rate for capital gains, a move that would mostly benefit the wealthy. Democratic bargainers are focusing on a five-year deficit-reduction plan, giving advocates of a capital gains tax cut a tough hurdle to clear, since CBO estimates it would lose revenue over the period.

Republicans, meanwhile, are adamant that tax rates not be touched. Between each party's stands, not much is left.

One option CBO Director Robert D. Reischauer is studying is the substitution of a 15 percent tax credit for itemized deductions. That would not affect taxpayers in the lowest bracket but would raise taxes in the others.

The measure would leave rates the same and raise about $8 billion in the first year and more than $30 billion over five years. "That allows people on both sides to preserve their positions," said Reischauer.