Declaratory Orders disposing of petitions have the same status as agency orders in contested cases. In the event that a Declaratory Order is contested, the tax administrator's prior acceptance of a factual presentation for purposes of rendering said order is not a waiver of his/her rights to cross-examine, supplement or rebut the taxpayer's factual recitals set forth in the request for the Declaratory Order.
280 R.I. Code R. 280-RICR-20-00-5.5