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Commercial smuggling is a large-scale criminal activity that can involve counterfeit state tax stamps, counterfeit versions of legitimate brands, and moving prohibited products.[12] The Mackinac Center provides several anecdotes of smuggling activity over the many editions of its report, including a prison guard caught smuggling cigarettes into prisons, a Maryland police officer running illicit cigarettes while on duty, and a Virginia man hiring a contract killer over a cigarette smuggling dispute.[13] International Smuggling and Counterfeiting Hurt Americans Smuggling that occurs within the borders of the United States is mostly a zero-sum activity from a cost perspective

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(3) requirements that are unique to tobacco product manufacturers, distributors, importers, and retailers