Pace Organization of Rhode Island v. Sarah Frew, in her capacity as Tax Assessor for the City of East Providence

Syllabus

The plaintiff, PACE Organization of Rhode Island, appealed from a Superior Court judgment entered in favor of the defendant, Sarah Frew, in her capacity as Tax Assessor for the City of East Providence, following the grant of the defendant's motion for summary judgment. On appeal, the plaintiff argued that the hearing justice erred by holding that G.L. 1956 § 44 3 3(a)(12) was ambiguous. The Supreme Court held that the relevant statute could reasonably be read in different ways and was therefore ambiguous. Because an ambiguity in a taxing statute must be resolved in favor of the taxing authority, the Supreme Court affirmed the judgment of the Superior Court.