R.I. Gen. Laws § 44-23.1-7 — Exoneration of fiduciary

Neither the fiduciary nor other person required to pay the tax is under any duty to
institute any suit or proceeding to recover from any person interested in the estate
the amount of the tax apportioned to that person until the expiration of the three
(3) months next following final determination of the tax. A fiduciary or other person
required to pay the tax who institutes the suit or proceeding within one year after
the three (3) month period is not subject to any liability or surcharge because any
portion of the tax apportioned to any person interested in the estate was collectible
at a time following the death of the decedent but thereafter became uncollectible.
If the fiduciary or other person required to pay the tax cannot collect from any person
interested in the estate the amount of the tax apportioned to the person, the amount
not recoverable is paid from the residuary estate. To the extent that the residuary
estate is not adequate, the balance is equitably apportioned among the other persons
interested in the estate who are subject to apportionment.