Many rational choice treatments of guerrilla insurgency have focused on the strategic calculus by which government and insurgent elites use the tactical weapons of coercion and benefits to win the support of nonelites. This paper uses Frohlich and Oppenheimer's model of the rational tax payer/tax evader to develop a model of the decision calculus by which nonelites respond to the tactical behavior of elites and thereby choose between supporting the incumbent regime, its insurgent opposition or neither. This model is then used to assess the likely impact of various insurgent and counterinsurgent tactics on nonelite support and loyalty.