P.R. Laws tit. 13, § 896
The Secretary of the Treasury shall, by registered mail, notify the administrator, executor, trustee, or grantor, as the case may be, of the appraisal of the said estates and of the tax he may determine, and any of them may, within the thirty (30) days following the mailing date of said notice, or within such extension of time as the Secretary of the Treasury may grant him for the purpose, apply to the latter in writing for a reconsideration of, and an administrative hearing on, the matter, setting forth in his application the reasons he may have therefor. If no recommendation is applied for in the manner and within the term herein provided, or if applied for, the Secretary of the Treasury confirms in whole or in part the appraisal and the tax determined and notified, the latter shall by registered mail, notify the administrator, executor, trustee, or grantor, as the case may be, of his final determination, and any one of them may appeal from said final determination to the Court of First Instance of Puerto Rico in the manner, within the term, and upon compliance with the requirements provided by law.
If the decision of the Court of First Instance or, on appeal the decision of the Supreme Court, is against the taxpayer, said judgment shall provide that the tax protested, or so much thereof as the said tribunal or court may deem correctly levied, be paid, together with interest thereon from the date of expiration of the term granted by law for the payment of the tax without interest.
If, upon appeal from a decision against the taxpayer, the decision of the Supreme Court of Puerto Rico should be in favor of the latter, and the taxpayer had paid the protested tax subsequently to the decision of the Court of First Instance, said decision shall direct the reimbursement to said taxpayer of the tax or so much thereof as said Court may deem was collected from him unlawfully or in excess, together with interest thereon at the rate of six percent (6%) per annum, computed from the date of payment of the protested tax.
History —Aug. 29, 1925, No. 99, p. 790, § 7; Apr. 27, 1933, No. 20, p. 232, § 3; May 12, 1936, No. 72, p. 370, § 3; Nov. 21, 1941, No. 20, p. 64, § 1; Apr. 12, 1946, No. 303, p. 782, § 15; May 14, 1947, No. 432, p. 882, § 2; May 14, 1948, No. 195, p. 554, § 1; May 10, 1949, No. 233, p. 724, § 1, eff. July 1, 1949.