ALBANY, N.Y., JULY 24 -- What is the likely fate of a presidential candidate whose record as governor offers the following horrors: His citizens are the most heavily taxed in the nation and his state ranks first in spending, first in borrowing, first in the size of its bureaucracy and third from last in its credit ratings?

Not good? How about the prospects for a presidential candidate with this record: He signed the two biggest tax cuts in his state's history. He built more prison cells than any governor. He invested heavily in education, the environment and economic development, and kept social service spending at the level needed to respond to the epidemics of AIDS, crack and homelessness.

Both records belong to one governor -- New York's Mario M. Cuomo -- and the way the two sides of this complex story are debated as he seeks reelection in a troubled time for his state's economy could serve as a dress rehearsal for the 1992 presidential election.

"He's going to be damaged merchandise by the end of this campaign," vowed Eddie Mahe, a veteran GOP consultant who is the chief strategist for Republican gubernatorial nomineee Pierre Rinfret. "I almost feel like I am working against my party's interests. Cuomo would be the best candidate for Bush to run against in 1992. But we may take him out before that."

While Cuomo has insisted he has no plans to run for president, his increasingly frequent attacks on the economic policies of the Reagan-Bush era -- and of the growing gap between rich and poor in America -- have led many Republicans to speculate that he will be the Democratic nominee.

The heart of the Republican case against Cuomo is that he is a big-spending liberal who has been, in a phrase Rinfret used Monday, "burning the furniture for firewood in Albany" by engaging in long-term borrowing and other fiscal chicanery to balance his annual budgets.

"Their case is pure froth," Cuomo, who has been a relentless critics of the budget deficits of the Reagan-Bush years, said in an interview. "If you honestly study the numbers, the debate is over in five minutes."

Here are some of the numbers that both sides will be serving up this fall -- and possibly again in two years:

Taxation: Rinfret claims that New Yorkers are the most heavily taxed Americans and that state taxes have risen 88 percent, or about twice the rate of inflation, in the eight years of the Cuomo administration.

Cuomo counters that he pushed through the two biggest tax cuts in state history and that, during his tenure, the top state income tax rate has fallen from the 10 percent he inherited in 1983 to 7.9 percent now.

The paradox is that both sets of facts are more or less correct.

The explanation goes to the political culture of the state. "New York used to be a very rich state, and it has always been a very liberal state . . . and the taste for taxing and spending is richer here than it is in virtually any other state," said Steven Gold, director of the State University of New York's Center for the Study of the States.

Additionally, from 1983 to 1988 New York experienced an economic boom in which the per capita income of New Yorkers increased from about 7 percent above the national average to about 15 percent above. The result was that, even as its high top tax rates were coming down, the taxes being paid were continuing to increase.

Cuomo argues that, when one considers state taxes only, New York ranks 19th in the nation in taxation as a percentage of personal income. His critics and many neutral observers maintain that it is better to measure both state and local taxes, since much of the local-government spending in New York is subject to mandates by the state government. On that measure, New York's tax burden ranks second only to Alaska's, where the taxes are paid more by oil companies than by individuals.

Spending: Again, the political culture of the state is unique: "Even the Republicans in New York are not exactly tight-fisted," noted Gold.

Cuomo argues on the campaign trail that Republicans who have controlled the state Senate for half a century have "raised my spending every year I've been in office."

"That's pure dissembling," said Rinfret's campaign manager, Assemblyman John Faso (R). "The governor has the line-item veto. If he wanted to cut the Republican spending, he could.In truth, Cuomo always leaves Republican programs out of his budget and forces us to negotiate them back in."

The fact that state and local governments in New York spend more per capita than any other state was true when Cuomo arrived and remains true today. Republicans note that during Cuomo's tenure spending has increased 91 percent -- more than twice the rate of inlfation -- and that it has also grown slightly as a percentage of New Yorkers' personal income.

Cuomo counters that his state's average annual spending increase between 1983 and 1990 has been 6.9 percent, which is less than the 7.7 percent average annual rate of the other 49 states over the same period. Cuomo's figure only includes general fund expenditures, however, and during his tenure the state's so-called "off-budget" spending has grown from an 8 percent share of overall state spending to a nearly 21 percent share. This off-budget spending, much of which involves semi-independent bonding authorities that Cuomo effectively controls, has more than tripled since he took office.

Borrowing: For generations, New York has borrowed more than any other state, and it has regularly done so in two especially pernicious forms: short-term roll-over borrowing, in which this year's money is used to pay last's years bills, and long-term borrowing, in which the state gives itself a generation's time to pay off current operating expenses.

Cuomo did not invent either practice. When he came to office as a would-be fiscal reformer, he inveighed against both. But, over time, he has resorted to both, especially in the last two years, as the state's softening economy has produced multi-billion-dollar budget shortfalls.

For example, in order to help close this year's budget gap, the state will sell the Cross Westchester Expressway to the New York Thruway Authority for $200 million. The Authority will buy the expressway by issuing bonds payable over 15 to 20 years. The state will spend the $200 million this year.

There are a half dozen more of such "one-shots" in this year's budget and "none of them passes the smell test," said Cynthia Green, director of the Citizen's Budget Commission, a watchdog group based in New York City.

Green praises Cuomo for taking steps this year to curb the state's annual practice of roll-over borrowing, but she blames both Cuomo and the legislature for not summoning the political will to "deal with the fact that our recurring revenues and our recurring expenses are out of line." That growing structural deficit led both Moody's and Standard and Poor's to reduce their ratings on New York's bonds this year to a level above only those of Louisiana and Massachusetts.

Even with the one-shots, Cuomo and the legislature has to raise taxes and fees by $1.8 billion this year. Next year, there are predictions that the budget shortfall will grow to $4 billion.

"Cuomo is going to have to face the kind of fiscal disaster in the year before he runs for president that {Massachusetts Gov. Michael S.} Dukakis faced the year after he ran," said Mahe. "And we're going to pound that theme this year."

Cuomo is mum on whether he will run for president. But he says he cannot wait to start the debate over his stewardship of the state's budget. "Their attacks will boomerang and hit them in the left jowl," he predicted. "And if they throw it low enough -- where they usually aim -- it will hit them someplace else. And that will be even funnier."