P.R. Laws tit. 21, § 5216
(a) Appraisal after notice of deficiency.— An appraisal under § 5214 of this title made after the taxpayer has been notified of the deficiency subject to such appraisal, pursuant to the provisions of § 5214 of this title will in no way affect the procedure established in § 5206 of this title nor shall it deprive the taxpayer of the resources provided therein with respect to said deficiency. When the appraisal is made after an administrative hearing concerning the deficiency subject to such an appraisal has been held, but prior to the Collection Center’s notice of its final decision, it shall notify the taxpayer as to said final determination within thirty (30) days following the date of said appraisal. Furthermore, when the appraisal of a deficiency under § 5214 of this title is made after sentencing by the Court of First Instance on the merits of said deficiency, the appraisal may only be made with respect to the amount of the deficiency determined by the judgment of the Court.
(b) Amount to be appraised prior to the Court of First Instance’s opinion.— The appraisal referred to in § 5214 of this title may be made with respect to a larger or smaller deficiency than that which has been notified to the taxpayer under § 5206 of this title, without considering the provisions of § 5209 of this title which prohibit the determination of additional deficiencies, or whether an appeal has or has not been filed before the Court of First Instance with regard to the notified decision. The Collection Center or its representative may reduce such an appraisal or any unpaid part thereof to the limit to which it considers the total amount of the appraisal to be excessive, at any time before the decision of said court is issued. The Collection Center shall notify the Court of First Instance of the amount of said appraisal or reduction should the appeal be filed before said court prior to the appraisal or subsequently filed, and the court shall have jurisdiction to redetermine the total amount of the deficiency and of all the amounts appraised at the same time with regard thereto.
History —Aug. 30, 1991, No. 83, § 6.16.