R.I. Gen. Laws § 44-19-13 — Notice of determination

(a) The tax administrator shall give to the retailer or to the person storing, using,
or consuming the tangible personal property a written notice of their determination.
Except in the case of fraud, intent to evade the provisions of this article, failure
to make a return, or claim for additional amount pursuant to §§ 44-19-16 — 44-19-19, every notice of a deficiency determination shall be mailed within three (3) years
after the fifteenth (15th) day of the calendar month following the month for which
the amount is proposed to be determined or within three (3) years after the return
is filed, whichever period expires later, unless a longer period is agreed upon by
the tax administrator and the taxpayer.
(b) Notwithstanding the provisions of subsection (a) of this section, under no circumstances
shall the tax administrator issue a notice of a deficiency determination for any sales
or use tax determined to be due and payable more than ten (10) years after the return
is filed, nor shall the tax administrator commence any collection action for any tax
that is due and payable unless the collection action is commenced within ten (10)
years after a notice of a deficiency determination becomes a final collectible assessment;
provided, however, that the tax administrator may renew a statutory lien that was
initially filed within the ten-year (10) period for collection actions. Both of the
aforementioned ten-year (10) periods are tolled for any period of time the taxpayer
is in federal bankruptcy or state receivership proceedings. “Collection action” refers
to any activity undertaken by the division of taxation to collect on any state tax
liabilities that are final, due, and payable under Rhode Island law. “Collection action”
may include, but is not limited to, any civil action involving a liability owed under
chapters 18, 18.1, 18.2, and 19 of title 44. This section excludes any sales and use
tax liabilities that are deemed trust funds as defined in § 44-19-35, as well as any meals and beverage tax liabilities that are collected pursuant to
§ 44-18-18.1, and any hotel tax liabilities that are collected pursuant to § 44-18-36.1.
(c) The ten-year (10) limitation shall not apply to the renewal or continuation of the
state’s attempt to collect a liability that became final, due, and payable within
the ten-year (10) limitation periods set forth in this section.