Ramón Quiñones v. Secretary of the Treasury

Mr. Justice Pérez Pimentel

delivered the opinion of the Court.

On September 3, 1950, the Treasurer of Puerto Rico, now Secretary of the Treasury, notified plaintiff-appellee of certain income-tax deficiencies for the years 1940 to 1946 inclusive. These deficiencies were due to the fact that the Treasurer (1) increased the gross income shown on the taxpayer’s return and disallowed certain deductions claimed; (2) disallowed the credits claimed as head of family and for dependents, and (3) assessed a penalty of 5 per cent of the total amount of the tax deficiency notified for each year.

The…