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Taken together, the Department of Labors statements could reasonably be read to require rebates of surcharges in cases where a participant starts the smoking cessation program when it is first-offered at the beginning of the year and completes it during the year, but not when the plan sponsor gives participants an additional non-required option to start the smoking cessation program in the middle of the year

[17] [18] Sponsorship [edit] Gold Flake was the main sponsor of the Gold Flake Open tennis tournament from 1997 until 2001

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