P.R. Laws tit. 13, § 33419

2019-02-20 00:00:00+00
§ 33419. Judicial review of partnership adjustment

(a) General rule.— Within ninety (90) days after the date on which a notice of a partnership adjustment is sent to the partnership with respect to any partnership taxable year, the partnership may file a petition with the Court of First Instance for a readjustment of the partnership items for such taxable year, filing a complaint as provided by law within a term of thirty (30) days after the mailing date of the notice of final determination, upon posting a bond in favor of the Secretary, before him and subject to his approval, in the amount stated in the aforementioned final determination; Provided however, That the taxpayer may pay the portion of the tax for which it agrees to be liable and litigate the remaining portion, in which case, the bond shall not exceed the amount of the litigated tax, plus interest, surcharges and any other additions to the tax on the deficiency computed in the manner provided in paragraph (1) [sic]. Except as otherwise provided in this subsection, the Court of First Instance shall not address the issue if the requirement to post a bond in the amount stated by the Secretary in the notice of final determination and to file a complaint with the Court of First Instance, both within the term provided above, are not met. The bond shall not exceed the amount of the notified tax, plus interest on the deficiency computed for the period of one additional year at a ten percent (10%) annual rate.

(b) The provisions of § 33002 of this title shall apply supplementarily to the provisions of this section, except for paragraph (1) and (2) of subsection (a) [sic].

History —Jan. 31, 2011, No. 1, added as § 6100.06 on Dec. 10, 2011, No. 232, § 186.