Supreme Court of Rhode Island December 11, 1996, No. 94-475-MP (Knaggs v. Clark)

OPINION

BOURCIER, Justice.

This case comes before us on a petition for certiorari brought by R. Gary Clark, the state tax administrator, seeking review 'of a final judgment of the Sixth Division District Court, in favor of the respondent-taxpayers, Ronald and Shelley B. Knaggs (the Knaggs). A District Court judge found that the federal tax on excess golden parachute payments, contained in I.R.C.