If the tax administrator believes that the collection of any amount of tax, interest, and/or penalty assessed in a notice of deficiency determination will be jeopardized by a delay that could render a person or entity judgment proof and/or frustrate the collectability of said determination, the tax administrator shall thereupon make a jeopardy determination of the amount of tax required to be collected, including interest and penalties, if any. Said jeopardy determination shall state briefly the facts upon which it is based. The amount of the tax, interest, and/or penalties so determined shall be due and payable immediately upon the mailing by the tax administrator of the notice of that jeopardy determination. Within thirty (30) days of the date of the mailing of the notice of the jeopardy determination, the taxpayer may bring an action in the sixth (6th) division district court appealing the jeopardy determination. Within twenty (20) days after the action is commenced, the district court shall make a determination of whether or not the making of the jeopardy assessment was reasonable under the circumstances.
R.I. Gen. Laws § 44-1-38