COLUMN LEFT/ LENNY GOLDBERG : Entitlements Subsidize More Than the Poor : The open-ended, uncapped ones enjoyed by the middle and upper classes should be cut.

President Clinton’s economic plan finally confronts, albeit timidly, a huge area of open-ended, uncapped entitlements: those in the tax code that accrue to the wealthy and the upper-middle class. The tax system provides on a daily basis subsidies of the consumption of food, shelter, entertainment, luxuries and other costs of living to those of us privileged enough to take advantage of them.

Perhaps the single most abused entitlement in the tax code is the deduction for business meals and entertainment expenses, which the Clinton program would cut from 80% to 50%.

The advantage of the business meal deduction is that it’s virtually impossible to audit--cash may change hands, dates are rarely on the check stubs, no one knows if business is actually discussed--and taxpayers get to write off as much as they feel won’t trigger IRS suspicion. A small-business tax newsletter, under the heading “When in doubt, deduct,” approvingly cites an insurance agent who routinely writes off the cost of entertaining his closest friends at home because they may someday become clients.

Entertainment deductions take a wide variety of forms, perhaps the most pervasive of which are sports tickets. It would appear that a meaningful percentage of the combined gates of major league baseball, the National Basketball Assn. and the National Football League are deductible from the taxes of countless businesses, large and small.

Clinton’s proposal to limit deductions to 50% makes the following statement: Half of your business meal will henceforth be considered food for personal consumption, and half will still be considered business. That’s generous; in fact, overly so for sports tickets, greens fees and opera boxes.

Then there’s housing. Ask a group of middle-class people if anyone lives in subsidized housing and none will raise their hands. But nearly all homeowners are subsidized, by the mortgage-interest deduction. The Clinton Administration rejected capping this deduction because the cost would fall disproportionately on heavily mortgaged California.

But subsidies go beyond the initial mortgage. It’s not just one home--it’s a second home or an RV or a yacht. For yachts to qualify for mortgage-interest deductions, they have to be large enough to have standing head room and a head, so boats of the working class need not apply.

Also, the deduction includes home-equity borrowing. My wife and I recently borrowed $50,000 on our house to remodel our kitchen--with skylights, a deck, wood floors, new appliances, the works. The combined interest deduction from state and federal taxes amounts to about one-third the total cost of the project.

The non-taxable capital gain on home equity buildup is another sweet entitlement, the equivalent of a long-term, zero-interest loan from the government to those fortunate enough to have their land values increase. And the greater the home appreciation, the greater the value of the subsidy. While “only” $125,000 of the gain is ultimately tax-free, if you’re able to hold the house so your children get it after you die, the gain is never taxed, even when the children sell the house.

Then there are cars, cellular phones and planes, all used for work and play--among the many (unauditable) expenses any self-employed professionals or business people can add to their business. Not to mention those deductible business trips.

Tax-free fringe benefits are a big-ticket entitlement. The ordinary working person who buys life insurance pays for it out of her hard-earned income. But the law partner or executive who gets insurance and other benefits as part of a “cafeteria plan” gets at least some of it tax-free. While there are limits on these deductions, by the time you put two executive jobs and two benefit packages together, the well-off working couple can get thousands in tax-free goodies, including, for example, employer-paid, tax-free child care.

The child-care credit is also a nice taxpayer gift for the deserving upper-middle class. When our own children were young, we received about $1,000 from the feds and $400 from the state to enable us to go out and earn the two professional incomes we would have earned anyway.

Many billions per year could easily materialize from capping, cutting and squeezing lifestyle subsidies in the tax code. But eliminating the deductibility of smaller costs such as the business golf game means more than the revenue--it goes to state of mind. Those who grouse about government waste at the 19th hole need to realize that they too are feeding at the trough.