Principles and Processes of Government Budgeting| Sin Taxes, Good or Bad? | An Examination of the Use of Sin Taxes in the United States| By: Stacy Madden4/27/2012 | Executive Summary Historically sin taxes have been an effective and efficient way for the government to raise revenue. The federal government used tariffs and consumption taxes to generate almost all of its revenue in the early years of our nation. The tax structure and philosophy has evolved and changed since the beginning of our nation, however the use of sin taxes has remained a good way for governments to raise revenues.
Sin taxes no longer provide a significant portion of federal or state governments; however they do provide a consistent stream of revenue. This paper examines the use of sin taxes in the United States. First, the paper provides a basic understanding of sin taxes, current definition, and history. Next, the paper outlines the goods and services most commonly targeted by sin taxes and provides information about the effectiveness of these taxes to raise revenue and accomplish policy outcomes.
Common goods and services targeted by sin taxes include; tobacco, alcohol, fuel, hazardous chemicals, gambling, prostitution, pornography, and unhealthy foods. Lastly, the paper will examine the ethical and moral implications of sin taxes from the perspective of those who support and oppose the use of sin taxes in the United States. Introduction Ben Franklin adequately stated the importance of taxes with his famous quote, “but in the world nothing can be said to be certain except death and taxes. Citizens have vested governments with the power to tax in order to provide services for the common good. There are many different ways for a government to tax its citizens in order to raise revenues, ranging from taxes on income, wealth, and property, to taxes on goods and services. The United States uses many of these taxes in varying levels to raise the needed funds to carry out government business. Some taxes are generally accepted and uncontested, while others are highly politicized and hard for Americans to accept.
Presently, the federal government relies on income taxes for the bulk of its revenue whereas states and localities rely more heavily on other forms of taxes to raise money for their functions. The primary function of taxes is to raise revenue for the government, however governments have used taxes to help spark social change, punish those who partake of certain goods and services, or regulate the consumption of specific goods and services. In these instances, taxes move from matters of revenue to issues of social policy, acting as mechanisms to force certain behaviors from citizens.
More specifically, sin taxes have been used in the United States to help change behavior or regulate the consumption of goods and services deemed as sinful. In this paper, I will define sin taxes and outline the political meaning of “sin,” provide a brief history of sin taxes and their use, examine the most common forms of sin taxes in the United States, and lastly discuss the ethical and moral implication of utilizing sin taxes as a mechanism of social change. Sin Tax, a Definition
Before considering the implications of sin taxes and their influence on the behavior of Americans, it is important to define the term. Taxes, most generally, are levied by governments to raise revenue in order to conduct business in the public interest. The United States, utilizing a progressive income tax to raise the bulk of its revenue, possess a culture where citizens pay most of their taxes on time. (Mikesell 493) This system is not one that commonly uses taxes as a punishment, instead encouraging its citizens to pay their taxes for the common good and success of the nation as a whole.
Noncompliance is low, and the government has even employed strategies to enhance payment, such as instruction and assistance. (Mikesell 494) Sin taxes, however, do not take this positive approach to raise revenue, instead, governments use their powers of taxation to punish behaviors when utilizing sin taxes. Most commonly, sin taxes are excise or consumption taxes that charge fees for guilty pleasures or human indulgence. Lorenzi, Sin Taxes 60) Sin taxes, therefore, are intended to encourage citizens to consume or use taxed items responsibly or discourage behavior associated with the consumption of taxed items. Goods or services generally taxed through sin tax policy have some common characteristics including inelastic demand, promote behavior that is harmful to the individual, and promote behavior that is harmful to others.
Goods or services targeted by sin taxes have an inelastic demand because they are generally habitual, addictive, or highly pleasurable. Lorenzi, Sin Taxes 60) Further, these goods or services are targeted by sin tax legislation because consuming or utilizing the good or services can lead to self-destructive behavior, negative consequences for communities, and generally are considered socially undesirable. Thus, sin taxes are not prohibitive; citizens are allowed to consume targeted goods and services as long as the tax is not steep enough to make consumption of the good or service impossible. Viscusi 556) Further, the voluntary nature of sin taxes is generally more tolerable than involuntary nature of income taxes. (Schmidt, Barr and Swanson 1677) The most confusing and controversial element when considering sin taxes is the definition of sin.
This word can be highly political and misleading, automatically making most think of sin in religious terms. However, sin, in the context of sin taxes, refers to addictive, self-destructive, and socially undesirable, behavior from the consumption of goods and services without crossing into religious doctrine. Lorenzi, Sin Taxes 60) In this context, then, sin is behavior that is undesirable enough to be targeted by taxes as a form of regulation or determent, but not so socially unacceptable to be illegal to the public. (Lorenzi, Sin Taxes 60) Therefore, sin taxes should not be considered as forms of punishment for poor consumption choices, but instead be a catalyst to foster sounder and safer decisions. (Viscusi 547) However, this can be a slippery slope, the limited use of taxes on goods and services deemed as sinful could grow and encompass others outside the scope of sin.
Sin Tax History Sin taxes have a long history, originating with religious doctrine and the power of organized religions to collect fees. Popes levied the earliest forms of sin taxes on prostitutes, brothels, and the sale of indulgence to raise money for religious projects. (Lorenzi, Sin Taxes 59) Laws required prostitutes to designate half of her property and fortune to convents, and brothels were taxed continuing through the 16th century. Lorenzi, Sin Taxes 59) Further, Russian Czar Peter the Great imposed fees on the length of beards to tax vanity, and the Puritans used sin taxes to curb extravagance. (Lorenzi, Sin Taxes 59)
The United States has a long history of utilizing taxes on socially undesirable goods and services to fund the government. In the early years of our democracy, the federal Government derived almost all its revenue from consumption taxes in the form of duties on imports and excise taxes on liquors and tobacco. American Economic Association 50) This tradition was set early when Congress enacted excise taxes on tobacco and snuff, refined sugar, distilled spirits, carriages, and property sold at auctions in order to finance the debts incurred during the Revolutionary War. (Hines 51) However, these taxes were not well received by a public that was over taxed by the British government and violent protests, in what was later coined the Whiskey Rebellion, resulted in the abolition of many unpopular excise taxes during the Jefferson Administration. Hines 52)
The War of 1812 and the Civil War both required the federal Government to raise revenue and as a result old excise taxes were reinstated as well as taxes on gold, jewelry, silverware, watches, playing cards, feathers, patent medicines, billiard tables, leather, telegrams, yachts, and many other luxuries, however these taxes were quickly repealed once the wars were over. (Hines 62) The federal Government was permitted to levy a personal income tax with the 16th Amendment, which became the main source of revenue in 1913. Hines) Federal excise taxes did not completely disappear during this time; however prohibition severely limited the possible revenue of excise taxes before the Depression.
The repeal of Prohibition and expansion of excise taxes on luxuries during the Depression helped to finance the increased federal spending of the New Deal Programs totaling more than 15 percent of the federal revenue in 1933. Hines 52) The expansion of programming during and following World War II required higher income taxes, fully transferring the bulk of government revenue away from excise and consumption taxes to the system we employ today. (Hines) The federal government still utilized some consumption and excise taxes, however these were limited to those goods and services mostly deemed socially undesirable, or sin taxes. Popular Goods and Services Taxed as “Sin” Tobacco and Alcohol The scope of goods and services targeted by sin taxes is limited in American society.
The two oldest and most widely targeted goods are tobacco and alcohol. As evidenced in the history of sin taxes, alcohol and tobacco have been taxed to finance federal and state governments, particularly in slow fiscal times or to raise money for major legislation or wars. These goods have been targeted by sin tax legislation because they have the potential to raise money rather quickly, have been relatively accepted as sinful, and have direct casual relationships with health or social problems. Hines 63) Further, it is easier for governments to justify taxes on tobacco and alcohol to the public since both goods tend to have negative consequences for the public at large. Legislators can disguise taxes on tobacco and alcohol as regulations to help protect society from the health and social consequences resulting from overconsumption of these goods while requiring those who consume tobacco and alcohol to finance the consequences of their consumption choices. (Boyd and Seldon 365) Thus, in times of increasing taxes it is easier and more popular to increase taxes on goods instead of taxes on income.
Cigarettes have been a major target of sin taxes in most recent history as the health risks have been widely publicized. In order to combat cigarette consumption, the federal government and many states have levied taxes on the production and/or sale of cigarettes. The rationale behind this tax is quite simple, those who partake in the pleasure of smoking should help pay for the health care required resulting from their choice. (Gruber 203) Today, all states and the federal government impose an excise tax on cigarettes, and these taxes are increasing as governments try to balance their budgets. American Medical Association 1909)
Cigarette excise taxes are widely accepted in public opinion, the hazards of smoking have demonized the industry and those who choose to purchase the products. (Gruber 194) Utilizing sin taxation to regulate consumption of tobacco has been highly effective, according to the CDC, “A 10% increase in the price of cigarettes can reduce consumption by nearly 4% among adults and can have an even greater effect among youths and other price-sensitive groups. (American Medical Association 1909) Sin taxation on alcohol, while a widely targeted good, seems to be less popular and publicized in popular media. Taxes on alcohol tend to be lower than those on tobacco, and many states handle the sale of alcohol differently (alcohol license tax, state operated liquor stores, etc. ), making the tax less visible to the public. (Johnson and Meier 580) Further, it is harder to gauge the effect specific liquor, beer, and wine taxes have on consumption.
For example, higher taxes increasing the price on one might cause consumers to substitute to another, more affordable alternative, such as substituting wine with beer. (Johnson and Meier 591) However, studies show increased prices on alcohol as a result of taxation have affected alcohol consumption rates to an extent even if it is minimal. (Boyd and Seldon 365) Sin taxation on both tobacco and alcohol have seemed to decrease the consumption of these goods while raising revenues for state and federal governments, however little attention is given to other factors affecting decreasing consumption rates.
The American public has been flooded with messages about the dangers of smoking and national campaigns have worked to warn Americans to stop smoking, helping to decrease cigarette consumption in the United States along with the steep sin taxes increasing the prices. Further, many cities and states are adopting smoking bans in public places, limiting the accessibility of facilities for smokers. Also, there are very few substitutes for tobacco products, forcing smokers to either pay the tax or consume less.
Political movements and tougher legislation against behavior resulting from alcohol consumption might be affecting consumption rates just as easily as increased prices resulting from sin taxes. Taxes on alcohol and tobacco can also increase production costs, causing producers to utilize their resources to raise other commodities that are not as heavily taxed, decreasing the overall production of tobacco and alcohol products. Boyd and Seldon 370) Further, lower consumption rates may not mean that consumption is actually dropping if consumers are turning to affordable black market substitutes. (Johnson and Meier 591) Environmental Americans have become increasingly accustomed to sin taxes that will help promote safer environmental practices and sustainability. Increased understanding of environmental factors surrounding pollution has increased the need for governmental regulation of emissions. As a result, the federal government has levied taxes on goods and services that contribute to pollution.
The most common of these taxes is that on fuel; gasoline and diesel. Sin taxes levied on gasoline are intended to discourage driving and reduce pollution as well as traffic congestion in the process. (Hines 52) This tax is easy for government to justify since the majority of funds raised from the tax are spent on highway maintenance and construction. (Hines 52) While this tax may not have been enacted with “sin” regulation in mind, environmental regulation helps to justify it now, putting it in the “sin” category.
Environmental sin taxes are not limited to fuel; they are also levied on gas-guzzler cars, heavy road vehicles, highway-type tires, and all forms of air transportation. (Hines 53) Ozone depleting chemicals also present an opportunity to tax environmental sin. Not only does the federal government limit the use of these hazardous chemicals, they are also taxed. (Hines 53) The strict regulation and higher taxes on these chemicals has severely reduced their production and use, almost making the usage limits irrelevant. Hines 53) In the future, scaled taxes on specific chemicals could help further reduce their use and potential harm to the ozone, however the federal government has not utilized sin taxes thoroughly enough to enact further environmental regulation. Gambling, Prostitution, and Pornography Gambling is a service that has been a target of sin taxes since the early years of our nation, easily defined as a sin but harder to single out and tax since it is not a good. The federal government has not taxed gambling with the same enthusiasm as tobacco, alcohol, or fuel taxes.
Taxing gambling in the United States is tricky, Native American and state sponsored gambling is tax free, and setting gambling taxes too high can cause taxpayers to turn to alternatives, such as illegal gaming establishments. (Schmidt, Barr and Swanson 1682) Further, it is harder for consumers to feel the effects of gambling taxes since most tax costs are not directly funded by service prices. Instead, most sin taxes are levied on the gaming establishments in the form of license agreements for specific games or total revenue. Schmidt, Barr and Swanson 1687) Thus, gambling taxes do not technically raise the cost of the service and encourage citizens to make better decisions, instead gambling establishments bear the majority of the burden of the tax cost. While gambling sin taxes are hard to levy on individuals for regulation, they can be a tool to monitor and stop organized crime through IRS oversight. (Schmidt, Barr and Swanson 1681) Prostitution and pornography are equally difficult to tax, each for their own, separate reasons.
Prostitution, while generally considered immoral, is legal in some states and on paper is considered victimless since it is a consensual act between two adults. (Lorenzi, Taxing Antisocial Behavior for the Common Good 331) Further, taxes in this industry generally are levied on the establishment, much like gambling, and if the tax becomes too high, consumers will look for substitutes, generally illegal. Pornography is equally as difficult to tax, since so much of this product is available online.
States are still trying to figure out how to charge a sales tax on online purchases, rather unsuccessfully, and pornography is no exception. Thus, taxes on this industry are limited to taxes on producers and networks, not individual consumers. (Lorenzi, Taxing Antisocial Behavior for the Common Good 331) In the end, taxes on prostitution and pornography are not as readily apparent to the consumer as with tobacco, alcohol or fuel, reducing the individual deterrent qualities of a sin tax on these goods and services. Fat Taxes
Obesity rates in the United States have been rising, and as a result so have health issues and healthcare costs. (Chaufan, Hong and Fox 87) In recent years, state and federal governments have debated utilizing sin taxes to raise the cost of purchasing calorie dense foods with no nutritional value in order to deter consumption. However, these “fat taxes” are not new and have been present since the 1920’s. (Creighton 127) They are gaining in popularity as the obesity epidemic continues to cause widespread health issues.
These unhealthy goods are particularly targeted by health officials because they are most commonly marketed to kids, and children who develop poor eating habits when they are young and more likely to become obese as adults. (Fletcher, Frisvold and Tefft 968) Thus, with evidence from the tobacco industry, sin taxes on unhealthy goods would seem to be a good method to encourage healthier food purchases. Further, taxing these goods could provide huge revenue increases for federal and state governments since the unhealthy food industry profits are similar to those of the alcohol industry. Fletcher, Frisvold and Tefft 968) Utilizing taxes as a mechanism to change behavior has not been as successful for curbing obesity. Taxing soft drinks has proved to discourage consumption, particularly for children and groups with limited spending capability. (Fletcher, Frisvold and Tefft 972) However, changing behaviors that lead to obesity takes more than just cutting specific foods out of a diet. For example, diets high in caloric intake can cause obesity regardless of where the calories are coming from if a person does not get enough exercise.
Curbing obesity almost requires a personalized plan for each individual, focusing not only on their diet, but also exercise habits, genetic makeup, and lifestyle. (Chaufan, Hong and Fox 88) Simply targeting one factor does not help fix problems with the other factors. Further, there are too many substitutes for unhealthy junk food, allowing citizens to continue to make poor health choices, even if we target certain goods. (O’Donoghue and Rabin 1841) Ethical and Moral Considerations of Sin Taxes
Sin taxes can be a valuable tool for government to raise revenue and help shape social policy. However, adding morals and values to a tax requires ethical and moral considerations above those of most other forms of taxes. These taxes are levied with a specific policy outcome in mind, yet sometimes it may be difficult to separate the government’s interest in raising revenue with the government’s overarching policy goal. Since these taxes generally have some sort of stigma attached with the goods or services taxed, it is also important to ensure these tax policies are enacted for the common good.
Sin taxes have been the target of moral and ethical discussions mainly because it is hard to decide what exactly constitutes a sin. Disputes arise as legislators decide what goods and services need to be regulated for the public wellbeing. While many of the goods and services taxed as sin have historically been deemed evil, immoral, seedy, or bad; discourse about who decides these products deserve to be regulated and taxed above and beyond other goods and services must be evaluated. This seems to be the central moral question surrounding sin taxes.
Should a minority of the population have to pay an extra tax to support the government simply because they partake or utilize a specific good or service? Taking this question a step further, sin taxes have the potential to raise large revenues, so is it ethical to make a few pay for government services for all? Who gets to decide how these funds will be spent, and who or what will this spending affect? (Green 70) The last overarching question surrounding the sin taxes focuses on the government’s power to tax, namely, can the government use its power to tax to shape and enforce social policies?
Those in favor of sin taxes would argue there are many reasons why it is moral and ethical to require consumers who purchase these particular goods and services to pay more than the average taxpayer. Namely, sin taxes target goods and services that cause negative consequences for the public at large. (Green 68) These could be increased health care costs or higher demand for social services. It is logical, then, to require these consumers to pay more since they are directly contributing to higher government costs for all.
Not only is it logical and moral to require these consumers to pay more for the added costs as a result of their consumption, higher taxes can help them make better, healthier choices. Sin taxes have been proven to reduce the consumption of specific goods and services, helping to create sustainable, prosocial behaviors for the future. (Lorenzi, Taxing Antisocial Behavior for the Common Good 328) Sin tax policies can help deter and regulate antisocial behaviors as a result of consumption of sin goods and services while simultaneously raising revenues to pay for the programming needed to help those affected by this behavior.
Further, sin taxes raising money on the backs of those partaking in antisocial behavior reduce the need to tax prosocial behaviors. For example, revenue generated from sin taxes can be used to fund government business, reducing income tax costs for the larger population. (Lorenzi, Sin Taxes) Targeting these immoral behaviors and using them to fund governmental operations ensures those engaged in prosocial behavior are not bearing a larger share of the cost of government. This is an attractive and easy sale to the public since higher taxes make all citizens unhappy.
Sin taxes on paper are extremely regressive, and as a result unfavorable to many. However, lifetime incidence studies prove the effects of these taxes on lower income taxpayers is about equal to those in middle or higher income households. (Poterba 327) Those who oppose sin taxes see the value they bring to both government revenues as well as the common good; however these positives do not outweigh the negative ethical and moral implications. First and foremost, opponents of sin taxes believe it is immoral for the government to rely on funding from the very behaviors it has deemed sinful and therefore is trying to regulate or change. Lorenzi, The Moral Grounds of Sin Taxes 68) Opponents see sin taxes as a stepping stone to banning certain goods and services, which should be a social policy decision supported by the public, not forced on them through prohibitive taxes. (Viscusi 547) Opponents therefore do not believe taxes should be used as a mechanism to enforce social policies or enact social change. (Creighton 135) In essence, the government is taking away the individual’s autonomy, legislating they should not purchase certain goods and products. (Green 72) This is a difficult issue to balance, Americans value independence and the freedom to choose.
Further, sin taxes are regressive, putting the large burden of payment on those with the least ability to pay. (Hines 65) In slow economic times, when governments tend to raise sin taxes to help close the revenue and expenditure gap, sin taxes could actually hurt the economy, pushing these citizens to the end of their economic resources. (Johnson and Meier 582) In the end, the same population the government is targeting to raise the revenue would be the same population in need of government services once their resources were depleted.
Further, utilizing sin taxes as a form of punishment or regulation directly competes with the message of the general tax code, namely, every citizen has the obligation to pay their taxes and support the government. The United States evolved their tax system from one based on consumption and tariffs to one based on taxing income based on the ability to pay. Sin taxes do not fit fairly into this carefully crafted tax structure we use today, sending the public mixed messages about citizen’s role in the taxation process. Lastly, opponents of sin taxes are skeptical if they are actually reaching the policy outcomes intended.
Studies show increased prices on certain goods and services reduces consumption, however there could be many other factors contributing to the decline in usage. For example, reduced consumption might be a result of heightened public awareness about the health risks, greater access to prevention and rehabilitation, harsher criminal legislation surrounding a specific behavior, or any number of other factors. Further, sin taxes on some goods, like unhealthy foods, really do not work at all since there are so many additional factors that might be contributing to the issue. Chaufan, Hong and Fox 87) Opponents also are skeptical sin taxes even reduce consumption since the presence of similar or equal substitutes might encourage consumers to find these goods and services elsewhere, such as illegal gambling establishments or black market cigarettes. (Johnson and Meier 591) The availability of substitutes could in turn create greater antisocial behavior and costs to the government in the form of criminal investigation, prevention, and added health risks from unsafe goods and services. Conclusion
Taxes are an inevitable fee all must pay to support the government. Citizens vest the power to tax with governments in return for government services. Governments take the power to tax a step further with sin taxes, not only raising revenue but also enacting or enforcing social policy. Sin taxes have been used successfully throughout history, particularly when citizens unanimously agree a sin exists. Sin taxes have also been successful in regulating or curbing consumption resulting in antisocial behavior as well as generating revenue.
On the surface, it would seem as if sin taxes are a great way to raise revenues and influence or enforce social policy. However, there are many ethical and moral implications surrounding sin taxes. Digging deeper into the positive and negative consequences of these taxes sheds light on the inherent problematic nature of the tax, and leads to questions about its place in the American tax structure. Legislators must be cognizant of these moral and ethical questions before deciding to enact taxes that could potentially be discriminatory to some members of society.
These taxes should be evaluated on a case by case basis, with clear and measureable policy outcomes included in the evaluation. Policy outcomes that are not easily measured may not be the best use of sin tax influence for social change. In the end, taxes on goods or services labeled as sinful have great potential to raise revenue, and as a result these taxes are popular to help close revenue and expenditure gaps. Perhaps sin taxes are a great case study for tax structures based on consumption instead of income. Hines 69) Sin taxes target consumption, and this seems to work well to raise revenue for the government. Many of the ethical and moral questions surrounding the use of sin taxes to influence social change could be eliminated within a tax structure based on consumption; however this shift would be a major tax reform in the United States. This may not be the answer we are looking for, yet sin taxes provide a window in which to examine tax policy, and possibly change the way our tax structures work in the future.
Works Cited American Economic Association. Consumption and Other Indirect Taxes. ” American Economic Review 9 (1919): 49-62. American Medical Association. “State Cigarette Excise Taxes-United States, 2009. ” MMWR: Morbidity and Mortality Weekly Report. 2010. Boyd, Roy and Barry J. Seldon. “Revenue and Land-Use Effects of Proposed Changes in Sin Taxes: A General Equilibrium Perspective. ” Land Economics 67. 3 (1991): 365-374. Chaufan, Claudia, Gee Hee Hong and Patrick Fox. “”Sin-Food” Taxes and Sugar-Sweetened Beverages–The Right Policy For the Wrong Reasons? ” American Journal of Health Promotion 25. (2010): 87-90. Creighton, Robert. “Fat Taxes: The Newest Manifestation of the Age-Old Excise Tax. ” Journal of Legal Medicine 31 (2010): 123-136. Fletcher, Jason M. , David E. Frisvold and Nathan Tefft. “The Effects of Soft Drink Taxes on Child and Adolescent Consumption and Weight Outcomes. ” Journal of Public Economics 94 (2010): 967-974. Green, Rebecca. “The Ethics of Sin Taxes. ” Public Health Nursing 28. 1 (2010): 68-77. Gruber, Jonathan. “Tobacco At the Crossroads: The Past and Future of Smoking Regulation in the United States. ” Journal of Economic Perspectives 15. (2001): 193-212. Hines, James R. Jr. “Taxing Consumption and Other Sins. ” Journal of Economic Perspectives 21. 1 (2007): 49-68. Johnson, Cathy M. and Kenneth J. Meier. “The Wages of Sin: Taxing America’s Legal Vices. ” The Western Political Quarterly 43. 3 (1990): 577-595. Lorenzi, Peter. “Sin Taxes. ” Social Science and Public Policy 41. 3 (2004): 59-65. —. “Taxing Antisocial Behavior for the Common Good. ” Society 47. 4 (2010): 328-332. —. “The Moral Grounds of Sin Taxes. ” Society 44. 1 (2006): 67-71. Mikesell, John L. Fiscal Administration. Belmont, CA: Thompson Wadsworth, 2007. O’Donoghue, Ted and Matthew Rabin. “Optimal Sin Taxes. ” Journal of Public Economics 90 (2006): 1825-1849. Poterba, James M. “Lifetime INcidence and the Diatributional Burden of Excise Taxes. ” American Economic Review 79. 2 (1989): 325-330. Schmidt, Robert, Charles F. Barr and David A. Swanson. “Socioeconomic Impacts of the Proposed Federal Gaming Tax. ” International Journal of Public Administration 20. 8-9 (1997): 1675-1698. Viscusi, W. Kip. “Promoting Smokers’ Welfare With Responsible Taxation. ” National Tax Journal 47. 3 (1994): 547-558.
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