P.R. Laws tit. 13, § 2239
If the Treasurer (a) determines that there is a deficiency with respect to the tax declared in accordance with the provisions of § 2236 of this title; or (b) has prepared an official declaration as provided in § 2237 of this title, he shall notify the taxpayer, by registered mail, of the deficiency determined in cases (a) and (b).
Within the thirty (30) days following the date said notice was mailed, or within the extension granted to him by the Treasurer for the purpose, the taxpayer may apply in writing to the Treasurer for a reconsideration of and an administrative hearing on, the matter, setting forth in his application the reasons he may have therefor. If the taxpayer does not apply for reconsideration in the manner and within the term herein provided, or if having made such application, the Treasurer should confirm in whole or in part the deficiency notified, the latter shall in both cases serve notice of his final decision on the taxpayer by registered mail, and the taxpayer may appeal from said final decision to the Court of First Instance, in the manner, within the term, and upon compliance with the requirements provided by law.
If the taxpayer is not satisfied with the deficiency or part of the deficiency determined by the Court of First Instance and wishes to appeal from said decision to the Supreme Court of Puerto Rico, under the law, he shall, however, be obliged to pay in full the deficiency thus determined within the term established by law to appeal to the Supreme Court, non-compliance with which requisite shall deprive the Supreme Court of jurisdiction in the case. If the judgment entered by the Supreme Court is favorable to the taxpayer, the Treasurer shall proceed to reimburse him, chargeable to any available funds in the Treasury, the amount of the judgment, plus interest on said sum at the rate of six percent (6%) per annum, from the date the writ of certiorari was filed in said court. If the Treasurer appeals to the Supreme Court from a decision of the Court of First Instance holding that a deficiency determined by the Treasurer does not exist, or that the same is less than as determined by said official, and the judgment rendered by said court is favorable to the Treasurer, the latter shall assess the tax according to said judgment, plus interest at the rate of six percent (6%) per annum from the date prescribed for the payment of the tax; and the taxpayer shall be obliged to pay said tax in full on demand of the Treasurer.
History —Apr. 6, 1946, No. 286, art. 1, § 9; May 10, 1949, No. 234, § 1, eff. July 1, 1949.