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Medical Expense Reimbursement Accounts Can't Pay Tax-Free for Expenses Before Plan's Adoption
Internal Revenue Service [IRS] 
[Official Guidance] Oct. 1, 2002
Rev. Rul. 2002-58. Excerpt: Amounts reimbursed under a self-insured medical expense reimbursement plan for medical expenses incurred by an employee prior to the establishment of the plan are not excludable from the gross income of the employee under section 105(b).
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