OPINION
MURRAY, Justice.
The defendant Tax Administrator (administrator) filed a petition for certiorari pursuant to G.L. 1956 (1977 Reenactment) § 42-35-16, seeking review of a Superior Court judgment ordering him to pay 8-percent annual interest on estate tax overpayments refunded to the plaintiffs (taxpayers). We issued the writ and have the pertinent records before us.
This controversy arose after an assessor for the state Division of Taxation...
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