Robert Schmidt v. Rhode Island Division of Taxation

Syllabus

This case came before the Supreme Court pursuant to a petition for writ of certiorari filed by the Rhode Island Division of Taxation, seeking review of a District Court judgment in favor of the respondents, Robert and Mary Schmidt. The sole issue was one of statutory interpretation—namely, whether the three-year refund period prescribed in G.L. 1956 § 44-30-87(a), which limits the amount that a taxpayer can recover for an overpayment of income taxes, refers to the three years following a taxpayer's filing of a tax return or the three years prior to a taxpayer's claim for a refund. This Court held that the three-year period in question refers to the three years after a return is filed. Accordingly, the Court quashed the judgment of the District Court.