The implementation of the Recovery Rebates offered to individuals in the CARES Act is challenging. There are a lot of situations for which the result under the statutory language is not clear. Tax practitioners want guidance and clarity. But the actual implementation of these provisions will be driven by more than the statutory language, legal analysis and policy considerations. To a large extent, it may be determined by computer limitations - the difficulty of programming in an antiquated system, and what can be programmed and tested quickly with a relatively low likelihood of significant glitches. The push to get money out quickly is an understandable reaction to the current crisis but it will challenge the capabilities of the IRS and its computer system.