If the tax administrator believes that collection of any tax or any amount of tax required to be collected and paid to the state or of any determination will be jeopardized by delay, the administrator shall thereupon make a determination of the tax or amount of tax required to be collected, including interest and penalties, if any, noting that fact upon the determination. The amount so determined is due and payable immediately upon the mailing by the tax administrator of the notice of that determination. Within thirty (30) days of the notice of jeopardy determination, the taxpayer may bring an action in the sixth (6th) division district court. Within twenty (20) days after the action is commenced, the district court shall determine whether or not the making of the jeopardy assessment is reasonable under the circumstances.
R.I. Gen. Laws § 44-19-15