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Last 24 hours there were 10 such txs confirmed according to one aggregate, so it's definitely still possible! I imagine at least in one situation where this might happen: a miner performs a low priority zero fee transaction and simply includes it in their block. Here's one from just 7 days ago: https://blockchain.info/tx/06d89bb591064c0c807ad2edb27656b49d4dae2f60181781d19b9939e7a09b8c