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Supreme Court No. 99-117-Appeal. (NC 91-48) (NC 92-300) (NC 94-23) (NC 95-215) (NC 95-216) Concurrence begins on page 11 Carol A. Cummings v. William H. Shorey, in his capacity as Tax Assessor for the Town of Middletown. : : :

Present: Weisberger, C.J., Lederberg, Bourcier, and Goldberg, JJ. OPINION Lederberg, Justice. The plaintiff, Carol A. Cummings, appealed to the Rhode Island

Supreme Court after her dispute over real estate taxes resulted in a judgment in favor of William H. Shorey (tax assessor or defendant), in his capacity as tax assessor of Middletown, Rhode Island. The plaintiff claimed that taxes on her property had been assessed illegally and that the revaluation was either not certified pursuant to law or was certified late, and she sought a refund of all taxes collected. We disagree and affirm the judgment. Facts and Procedural History The plaintiff owns several parcels of ratable real estate in the Town of Middletown, Rhode Island. In the course of the town's revaluation of all taxable real estate, plaintiff initially sought relief from the Middletown Board of Tax Appeals (board) for what she alleged was an illegal assessment of her

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properties. The plaintiff stipulated that the board granted her some reduction in assessments, but she was afforded no relief on the alleged illegal tax assessment process. The plaintiff filed tax appeals under G.L. 1956

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Rhode Island Law