P.R. Laws tit. 13, § 33422
(a) In general.— If any part of an administrative adjustment request filed under § 33421 of this title is not allowed by the Secretary, the partnership may file a petition for an adjustment with respect to the partnership items to which such part of the request relates.
(b) Period for filing petition.— A petition may be filed under subsection (a) with respect to partnership items for a partnership taxable year only.
(1) After the expiration of six (6) months from the date of filing of the request under § 33421 of this title, and
(2) before two (2) years after the date of such request.
The two (2)-year period set forth in clause (2) of this subsection shall be extended for such period as may be agreed upon in writing by the partnership and the Secretary.
(c) Coordination.—
(1) Notice of partnership adjustment before filing of petition.— No petition may be filed under this section after the Secretary mails to the partnership a notice of a partnership adjustment for the partnership taxable year to which the request under § 33421 of this title relates.
(2) Notice of partnership adjustment after filing but before hearing of petition.— If the Secretary mails to the partnership a notice of a partnership adjustment for the partnership taxable year to which the request under § 33421 of this title relates after the filing of a petition under this subsection, but before the hearing of such petition, such petition shall be treated as an action brought under § 33419 of this title with respect to such notice, but the bond required under § 33419(a)(2) of this title shall not be required.
(3) Notice must be before expiration of statute of limitations.— A notice of a partnership adjustment for the partnership taxable year shall be taken into account under clauses (1) and (2) of this subsection only if such notice is mailed before the expiration of the period prescribed by § 33420 of this title for making adjustments to partnership items for such taxable year.
(d) Scope of judicial review.— Except in the case described in subsection (c)(2) of this section, the Court of First Instance shall have jurisdiction to determine only those partnership items to which the part of the request under § 33421 of this title not allowed by the Secretary relates and those items with respect to which the Secretary asserts adjustments as offsets to the adjustments requested by the partnership.
History —Jan. 31, 2011, No. 1, added as § 6100.09 on Dec. 10, 2011, No. 232, § 186.