R.I. Gen. Laws § 44-40-11
The person liable for the tax imposed by this chapter may, within three (3) months after receipt of notice of deficiency, apply to the sixth division of the district court, by a complaint against the administrator pursuant to chapter 8 of title 8, for the abatement of the tax or any part of the tax or a deficiency or any part of a deficiency. If the court adjudges that the tax or any part of the tax, or any deficiency or any part of a deficiency, is unfair or excessive or was illegally assessed, it shall order an abatement of the tax or that portion of an abatement, or deficiency or any part of a deficiency, that is unfair or excessive or was illegally assessed, and that order shall be subject to appeal. A party aggrieved by a final order of the court may seek review of the order in the supreme court by writ of certiorari in accordance with the procedures contained in § 8-8-32.
R.I. Gen. Laws § 44-40-11