OPINION
KELLEHER, Justice.
This controversy comes before us on an appeal from a Superior Court judgment that voided tax assessments made by the city of Newport on a fifty-eight-room resort for the fiscal years 1983 through 1987.
The defendants in the original action and the appellants before us now are Allan Booth, Jr., in his capacity as tax assessor (assessor) of the city of Newport, and Joseph Crawshaw, in his capacity as collection supervisor...
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