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A sizable literature of peer-reviewed academic studies supports these observations.[9] A 2017 study published in Public Finance Review provides the academic theory and estimates for how tax rates affect smuggling, highlighting that easily transportable goods (e.g., cigarettes) will be attractive cross-border shopping items.[10] A 2018 study published in the same journal supported those findings by examining littered packs of cigarettes across 132 communities in 38 states, finding that 21 percent of packs did not have proper local stamps.[11] Smuggling comes in different forms

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One product, Newport Non-Menthol, is advertised for example as The non-menthol for menthol smokers. California Attorney General Rob Bonta and tobacco control advocates argue the products are flavored and are an end-run around California law, but Reynolds has argued the products do not impart a distinguishable taste or aroma other than tobacco, and thus can legally be sold

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