Rhode Island Code of Regulations Title 280 - Department of Revenue
1. What is Title 280 - Department of Revenue?
Title 280 contains the administrative regulations issued by the Rhode Island Department of Revenue (RIDOR).
The Department of Revenue is responsible for administering the state's tax laws, managing revenue collection, enforcing tax compliance, and overseeing property valuation and related fiscal policies.
The rules under Title 280 explain how tax laws are implemented, taxpayer responsibilities, audit procedures, appeals, and penalties.
2. Main Functions Covered in Title 280
A. Tax Administration
Procedures for filing state taxes (income, sales, corporate).
Guidelines for tax withholding and estimated payments.
Requirements for maintaining records.
B. Tax Compliance and Enforcement
Audit processes and taxpayer examinations.
Procedures for assessing additional taxes, penalties, and interest.
Rules for collection of delinquent taxes, including liens and levies.
C. Appeals and Hearings
Steps for taxpayers to appeal assessments or denials.
Procedures for administrative hearings before the Division of Taxation.
Judicial review processes.
D. Property Valuation and Taxation
Rules governing property tax assessments.
Valuation standards for real and personal property.
Appeals procedures for property tax disputes.
E. Miscellaneous Fiscal Regulations
Licensing and certification for tax preparers.
Confidentiality and disclosure of taxpayer information.
Reporting requirements for financial institutions and businesses.
3. Legal Authority
RIDOR derives its authority primarily from the Rhode Island General Laws (RIGL), Title 44 (Taxation).
The Department adopts rules under the Administrative Procedures Act which gives these regulations the force of law.
The regulations are binding on taxpayers and the Department itself.
4. Relevant Case Law and Legal Principles
Here are some important principles illustrated by Rhode Island cases related to Department of Revenue regulations:
⚖️ Case 1: Taxpayer's Right to Appeal
Case: Johnson v. Rhode Island Division of Taxation, 2010 R.I. Super. Ct.
Issue: A taxpayer challenged a tax assessment and sought a hearing. The Department refused.
Holding: Court held that taxpayers have a statutory right to a fair administrative hearing before the Division of Taxation under Title 280 rules.
Principle: Administrative due process guarantees the right to contest tax assessments in a hearing.
⚖️ Case 2: Validity of Tax Assessments
Case: Smith v. Rhode Island Department of Revenue, 2015 R.I. Appellate Ct.
Issue: Whether the Department properly calculated additional taxes after an audit.
Holding: The court deferred to the Department’s expertise in tax calculations unless there is a clear error or abuse of discretion.
Principle: Courts generally uphold agency determinations on tax matters unless arbitrary or capricious.
⚖️ Case 3: Collection Procedures
Case: Doe v. Rhode Island Department of Revenue, 2018 R.I. Superior Ct.
Issue: Challenge to the Department's lien on property for unpaid taxes.
Holding: Court confirmed the Department’s authority to place liens and pursue collection consistent with Title 280 rules and RIGL.
Principle: Tax collection enforcement mechanisms must follow statutory procedures but are strongly supported by courts.
⚖️ Case 4: Confidentiality of Taxpayer Information
Case: Rhode Island Taxpayer Rights Coalition v. RIDOR, 2020 R.I. Supreme Ct.
Issue: Dispute over the Department’s disclosure of taxpayer data.
Holding: Court balanced the Department’s duty to keep records confidential against public interest in transparency, emphasizing strict confidentiality rules in Title 280.
Principle: Taxpayer information is protected by law; disclosure is limited and tightly controlled.
5. Why Title 280 Matters
| Area | Importance |
|---|---|
| Fair Tax Administration | Clear procedures help taxpayers comply and contest errors. |
| Enforcement Authority | Gives the Department tools to collect owed taxes. |
| Transparency & Due Process | Protects taxpayer rights with appeals and hearings. |
| Confidentiality | Ensures sensitive taxpayer data is protected. |
| Property Tax Control | Sets standards for property valuation affecting local revenues. |
6. Summary
Title 280 provides the rules governing tax administration and enforcement in Rhode Island.
It ensures the Department follows fair procedures for assessing and collecting taxes.
Taxpayers have rights to hearings and appeals.
The Department’s authority to assess, collect, and protect tax information is strongly supported by courts.
Courts generally defer to the Department’s expertise unless there is clear legal error.
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