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HSAs Established Before April 15, 2005 Can Cover Expenses Incurred On or After January 1, 2004 (PDF)
Internal Revenue Service [IRS] 
[Official Guidance] Mar. 30, 2004
3 pages; IRS Notice 2004-25. Excerpt: This notice provides transition relief for calendar year 2004 for eligible individuals who establish an HSA or on before April 15, 2005 from the requirement that qualified medical expenses may only be paid or reimbursed by an HSA if incurred after the HSA has been established.
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