Cia. Azucarera del Toa, Inc. v. Tax Court of Puerto Rico

Mr. Chief Justice Todd, Jr.,

delivered the opinion of the Court.

In April and July 1941, the Treasurer of Puerto Rico sent petitioner herein notices of income tax deficiencies, plus interest and penalties, for the years 1935, 1937, 1938 and 1939, amounting to $12,321.15, $6,718.24, $27,834.67 and $5,339.79, respectively. He also determined that for the year which ended June 30, 1936, the petitioner was entitled to a refund amounting to $250.20. However, no credit was allowed nor refund made because, as the Treasurer claimed, the four-year period provided by § 64(6) of the Income Tax Act had…