- 7 - (9th Cir. 1984); Abeles v. Commissioner, 91 T.C. 1019, 1032 (1988). Because of the large number of tax returns filed with respondent on or around April 15 and as a matter of “practical operational necessity”, respondent is allowed, after receipt, a reasonable period of time to process and to post to respondent’s computer systems new addresses of taxpayers. Williams v. Commissioner, 935 F.2d 1066, 1068 (9th Cir. 1991), affg. T.C. Memo. 1989-439. Whether respondent exceeded a reasonable period of time to process and to post new addresses involves a question of fact. Id. Petitioner contends: (1) That respondent’s May 17, 1999, Levy Letter was not mailed to his last known address; (2) that he did not receive the May 17, 1999, Levy Letter mailed to his Desert Inn address; (3) that respondent’s May 17, 1999, Levy Letter did not constitute proper notice of his right to a CDP hearing with regard to the levy notice; and (4) that we therefore should enjoin respondent’s proposed levy. We disagree. Particularly in light of the fact that petitioner’s 1998 Federal income tax return constituted an incomplete return, a 32-day period did not exceed a reasonable period of time for respondent to post petitioner’s Nightflower address to respondent’s computer system. Rev. Proc. 90-18, 1990-1 C.B. 491, 494. Accordingly, respondent, in this case, wasPage: Previous 1 2 3 4 5 6 7 8 Next
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