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[51] Michael LaFaive et al., Cigarette Taxes and Smuggling: A Statistical Analysis and Historical Review, Mackinac Center for Public Policy, 2008, 18, [52] William Orzechowski and Robert Walker, The Tax Burden on Tobacco: Historical Compilation Volume 59, 2024 (Orzechowski & Walker, 2025), 12

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That lack of enforcement has left the courts conflicted about whether merchants are still obligated to collect the tax, and whether they can be prosecuted if they don't