As Quine wrote in his original criticism of Smullyan, for a formal language (without intensional contexts and not in natural language in other words, we eliminate Quine's original errors), under reasonable hypotheses (actually, Quine ignores the case of descriptions with variables, where the Hilbert Bernays hypotheses we have been using are rather strong), if descriptions are thought of as terms it is unnatural to have scope distinctions in the language.