Section 280-RICR-20-25-10.21 - Special AppealsA. If at any time the Tax Administrator, on his own motion or acting upon a complaint by a taxpayer, determines that the methods of apportionment provided are inequitable either to the State or to the taxpayer, the Tax Administrator - after affording the taxpayer reasonable opportunity to be heard - may apply any other method of apportionment that is equitable and, if necessary, shall re-determine the tax.B. The Division of Taxation is required by statute to establish an independent appeals process - for tax years beginning on or after January 1, 2015 - to attempt to resolve disputes between the Tax Administrator and the taxpayer with respect to the method of apportionment applied regarding the corporate income tax under R.I. Gen. Laws Chapter 44-11, including combined reporting. The Division of Taxation intends to address the requirement in the following manner: 1. When a dispute arises between the Tax Administrator and a taxpayer with respect to the method of apportionment applied, both the taxpayer and the Tax Administrator shall be entitled to initiate an appeals process through an independent arbitrator. The Division of Taxation's regulation on apportionment provides additional information on this matter. It is recommended that the Tax Division's regulation on apportionment be read in concert with the Tax Division's regulation on combined reporting.280 R.I. Code R. § 280-RICR-20-25-10.21