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In other words, if a non-smoking participant is required to pay $$400 and a smoker is required to pay $600, it makes no sense to say that calling the extra $200 a surcharge is impermissible, but calling it a $200 discount for non-smokers is fine

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The main reasons for this new trend include the adoption of a minimum age 21 to purchase tobacco products in New York City and the FDA-sponsored Institute of Medicine study that researched the public health impact of raising the legal age to 21 or 25 and concluded that raising the legal age to 21 would reduce the number of underage youth that begin using tobacco products