R.I. Gen. Laws § 44-14-19.2 — Limitations on assessment

(a) General. Except as provided in this section the amount of the excise tax shall be assessed
within three (3) years after the return was filed (whether or not the return was filed
on or after the prescribed date). For this purpose, a tax return filed before the
due date shall be considered as filed on the due date.
(b) Exceptions.
(1) The tax may be assessed at any time if:
(i) No return is filed.
(ii) A false or fraudulent return is filed with intent to avoid tax.
(2) Where, before the expiration of the prescribed time in this section for the assessment
of tax, or before the time as extended under this section, both the tax administrator
and the taxpayer have consented, in writing, to its assessment after that time. The
tax may be assessed at any time prior to the expiration of the agreed upon period.
(3) An erroneous refund shall be considered to create an underpayment of tax on the date
made. An assessment of a deficiency arising out of an erroneous refund may be made
at any time within three (3) years thereafter, or at any time if it appears that any
part of the refund was induced by fraud or misrepresentation of a material fact.
(c) Notwithstanding the foregoing provisions of this section, the tax may be assessed
at any time within six (6) years after the return was filed if a taxpayer omits from
its income an amount properly includable in the return which is in excess of twenty-five
percent (25%) of the amount of income stated in the return. For this purpose there
shall not be taken into account any amount which is omitted in the return if the amount
is disclosed in the return, or in a statement attached to the return, in a manner
adequate to apprise the tax administrator of the nature and amount of the item.
(d) The running of the period of limitations on assessment or collection of the tax or
other amount (or of a transferee’s liability) shall, after the mailing of a notice
of deficiency, be suspended for any period during which the tax administrator is prohibited
from making the assessment or from collecting by levy, and for sixty (60) days after
this.
(e) No period of limitations specified in any other law shall apply to the assessment
or collection of taxes due under this chapter.