R.I. Gen. Laws § 44-23-9 — Assessment and notice of estate tax — Collection powers — Lien

(a) The tax imposed by § 44-22-1.1 shall be assessed upon the full and fair cash value of the net estate determined
by the tax administrator as provided in this chapter. Notice of the amount of the
tax shall be mailed to the executor, administrator, or trustee, but failure to receive
the notice does not excuse the nonpayment of or invalidate the tax. The tax administrator
shall receive and collect the assessed taxes in the same manner and with the same
powers as are prescribed for and given to the collectors of taxes by chapters 7 —
9 of this title. The tax shall be due and payable as provided in § 44-23-16, shall be paid to the tax administrator, and shall be and remain a lien upon the
estate until it is paid. All executors, administrators, and trustees are personally
liable for the tax until it is paid.
(b) Notwithstanding the provisions of subsection (a) of this section, under no circumstances
shall the tax administrator issue any notice of deficiency determination for the amount
of the estate tax due more than ten (10) years after the return was filed, nor shall
the tax administrator commence any collection action for any estate tax due and payable
unless the collection action is commenced within ten (10) years after the date a notice
of deficiency determination became a final collectible assessment. “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 22 and 23 of title 44.
(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.