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The [tax] administrator must face not only the possibility of smuggling from non-taxing states but from adjacent states with tax rates that are from one cent to several cents lower.[161] While smugglers improved their counterfeiting operations, thefts of unstamped and legally stamped, tax-paid cigarettes along the distribution chain became more frequent during the late 1950s

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New York has the highest inbound smuggling activity, with an estimated 54.3 percent of cigarettes consumed in the state deriving from smuggled sources in 2022