If the Collection Center has sent a notice of deficiency to the taxpayer by certified mail as provided by § 5206 of this title, and the taxpayer has resorted to the Court of First Instance within the term and in the manner provided, the Collection Center shall not be entitled to determine any additional deficiency regarding to the same taxable year, except in the case of fraud, and except as provided by § 5208 of this title (concerning the power of the Court of First Instance to determine deficiencies).
History —Aug. 30, 1991, No. 83, § 6.09.