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Commentary on HSA Substantiation (PDF)
Urban Institute 
[Opinion] May 27, 2008
Excerpt: The problem is that, under current law, there is no way -- short of a tax audit -- to tell if tax-advantaged withdrawals from these accounts are legal or illegal. People don't have to verify whether they made a withdrawal for the copay on their child's asthma inhaler or whether it was for gourmet chocolate truffles. Since annual contributions to HSAs can be $2,900 for a single plan and $5,800 for a family plan, that can mean a lot of tax-free truffles, and a tax loss for the federal Treasury.
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