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Presumably the states will provide some non-quantitative evidence indicating how hard they have worked at enforcement, but how do you persuade the arbitrator that youve been diligently enforcing the tax when your own estimate of the compliance rate is so low? Bulow said that it was almost inevitable that the diligent enforcement clause would cause problems for the states

A pack-year is calculated by multiplying the number of packs of cigarettes smoked per day by the number of years smoked

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