(a) General rule. —(1) If a credit or refund claim in connection with any taxes imposed by this Code which was filed by a taxpayer is totally or partially denied by the Secretary, he/she shall notify so to the taxpayer via certified mail, and the taxpayer may resort against such denial before the Court of First Instance by filing a lawsuit in the manner provided by law within thirty (30) days following the date in which such notice was mailed.(2) Failure to file a lawsuit within the term provided herein shall divest the Court of First Instance of competence to review the matter.(3) Notwithstanding the provisions of §§ 2101 et seq. of Title 3, or any other law which replaces or complements the same, the taxpayer affected by a total or partial denial of a credit or refund in connection with any taxes imposed by this Code shall have no right to request an informal hearing or any other administrative procedure before the Secretary, being only able to seek remedy by resorting to the Court of First Instance within the term provided herein.(4) Against any judgment pronounced by the Court of First Instance granting or refusing to grant a credit or refund requested pursuant to this

Court of First Instance within the term provided herein.(4) Against any judgment pronounced by the Court of First Instance granting or refusing to grant a credit or refund requested pursuant to this subsection, the taxpayer or the Secretary, as the case may be, may resort to the Court of Appeals by filing a writ of appeal with the Office of the Clerk of such Court within thirty (30) days following the entry into records of a copy of the notice concerning the judgment pronounced by the Court of First Instance.(5) Against the judgment pronounced by the Court of Appeals granting or refusing to grant a credit or refund requested pursuant to this subsection, the taxpayer or the Secretary, as the case may be, may resort to the Supreme Court by filing a writ of certiorari or appeal with the Office of the Clerk of such Court within thirty (30) days following the entry into records of a copy of the notice concerning the judgment pronounced by the Court of Appeals.(b) Limitation. — The Court of First Instance shall not consider any recourse whatsoever to claim a credit or refund in connection with any taxes imposed by this Code unless there is a denial by the Secretary regarding such

urt of First Instance shall not consider any recourse whatsoever to claim a credit or refund in connection with any taxes imposed by this Code unless there is a denial by the Secretary regarding such credit or refund, notified as provided in subsection (a). History —Jan. 31, 2011, No. 1, § 6025.01, retroactive to Jan. 1, 2011.