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In a study performed by Murayama-Sung et al

Closed systems typically have higher nicotine content than open systems.[77] Thus, legislators could consider establishing a tiered system, where open refillable systems are taxed at a lower rate than closed systems, with different rates designed to equalize taxation and keep it neutral, not introduce unnecessary disparities

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If the taxpayer buys from other than a manufacturer, wholesale price means the invoice price, including all federal excise taxes and excluding any discounts based on the method of payment of the invoice or on time of payment of the invoice