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The report noted that while CHIPRA raised tax rates on all types of tobacco products, it raised the rate on pipe tobacco and large cigars by a lesser amount, creating a substantial tax disparity easily visible to consumers

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"The process of selling loose untaxed tobacco, which is then immediately rolled into cigarettes retained by the customer in cigarette rolling machines conveniently located on the premises, is clearly a subterfuge to circumvent statutory requirements," wrote Judge Larry Smukler