R.I. Gen. Laws § 44-19-19 — Judgment on review

If, upon final determination of the petition, it appears that the tax administrator’s
assessment was correct, the court shall confirm the assessment; or, if incorrect,
the court shall determine the proper amount of the tax, interest, and penalties, and
if it appears that the petitioner, by reason of the payment of the tax, interest,
and penalties, is entitled to recover them or any part of them, the court may order
a refund with interest at the annual rate provided by § 44-1-7.1 or order a credit, as the circumstances may warrant. If a refund is ordered, it is
paid by the general treasurer upon certification of the tax administrator with the
approval of the director of administration. If it appears that the state is entitled
to a greater amount of tax, interest, and penalties than assessed or determined by
the tax administrator and paid by the petitioner, the court shall order the payment
by the petitioner of an additional amount as the court determines, and the petitioner
shall immediately pay that amount to the tax administrator.