Ramos v. Secretary of the Treasury

In general terms the Secretary of the Treasury is barred from assessing a deficiency or to proceed to collect it by distress proceeding or judicially until he has served a notice of deficiency as provided by § 57 (a) (1) of the Income Tax Act of 1924, 13 L.P.R.A. § 775(a) (1), § 272(a) (1) of the Income Tax Act of 1954, 13 L.P.R.A. § 3272(a) (1). The purpose of this provision is to give the taxpayer the opportunity to contest his tax responsibility, either administratively, if he chooses to request a hearing before the Bureau, or judicially, if he prefers to appeal to the courts to review the…