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Two different manufacturers may sell an orange flavored e-liquid, but they could each contain vastly different flavorants to get that orange flavor, Bitzer said

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The Supreme Court sided with the plaintiff that the Citys ordinance is preempted by the Illinois Municipal Code, which states home rule municipalities that have not imposed a tax based on the number of units of cigarettes or tobacco products before July 1, 1993, shall not impose such a tax after that date. While the City had a cigarette tax in 1993, it did not impose a tax on other tobacco products until 2016

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