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Significantly, although the department explains that it will escalate penalties if a licensee continues to violate regulations, DCC does not provide specific guidance on how to escalate penalties, and we found little evidence that it did so

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Morris Coats, A Note on Estimating Cross-Border Effects of State Cigarette Taxes, National Tax Journal 48:4, (December 1995), 573-584, ntj-v48n04p573-84-note-estimating-cross-border.pdf?v=%CE%B1&r=35923133871196367

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