R.I. Gen. Laws § 44-11-15 — Variation of method of allocating income

If at any time the tax administrator, on his or her own motion or acting upon a complaint
by a taxpayer, determines that the methods of allocation provided are inequitable
either to the state or to the taxpayer, the tax administrator, after affording the
taxpayer reasonable opportunity to be heard, may apply any other method of allocation
that is equitable and, if necessary, shall redetermine the tax.
The division of taxation shall establish an independent appeals process to attempt
to resolve disputes between the tax administrator and the taxpayer with respect to
the method of allocation applied. The decision resulting from the independent appeals
process shall not prohibit either party from pursuing any legal remedy otherwise available
if the issue is not resolved as a result of the appeal process. The decision resulting
from the independent appeals process can be used as evidence.