Tennessee Code Annotated
Tenn. Code Ann. § 34-1-112 (2026)
Compensation to fiduciary
✓ current as of May 2026
- (a) The fiduciary may receive reasonable compensation for services rendered. The court shall set the actual compensation to be paid, taking into account:
- (1) The complexity of the property of the minor or person with a disability;
- (2) The amount of time the fiduciary spent in performing fiduciary duties;
- (3) Whether the fiduciary had to take time away from the fiduciary's normal occupation;
- (4) Whether the services provided the minor or person with a disability are those the fiduciary should normally have provided had there been no need for a fiduciary, and
- (5) Such other matters as the court deems appropriate.
- (b) No person, other than a person performing temporary fiduciary services while a proceeding is pending, who has not been appointed by the court to serve as a fiduciary shall receive any compensation for fiduciary services; however, this does not preclude payment for the necessary care of the minor or person with a disability.
- (c) No compensation to the fiduciary shall be paid without prior court approval.
Acts 1992, ch. 794, § 13; T.C.A. § 34-11-112.
Notes of Decisions
Cited in 4
cases (2 in the last 5 years), 2005–2026 · leading case: In Re Conservatorship of Betty A. Winston (Tenn. Ct. App. 2026).
In Re Conservatorship of Betty A. Winston (Tenn. Ct. App. 2026). “” Tenn. Code Ann. § 34-1-112 (c). After hearing Appellant’s testimony, the trial court ruled that Appellant “breached her fiduciary relationship as to some expenditures because such were not expenditures for the benefit or protection of [Ward], or were compensation without prior…”
In Re: The Conservatorship Of Mary Ruth Davis Hudson, 578 S.W.3d 896 (2018). “Tenn. Code Ann. § 34-1-112 (a). “When a party having an interest in a disabled person’s estate challenges a conservator’s final accounting, the burden is on the conservator to establish the correctness of the accounting.”
In Re Conservatorship of Patricia L. Capelli (2025). “See Tenn. Code Ann. § 34-1-112 (a). In support of this filing, Dr.”
In the Matter Of Eugene Burnett Ellis v. Jerry Glenn Ellis & Sarah L. Kerley, Glen C. Shults, Guardian ad Litem (Tenn. Ct. App. 2005). “Shults has appealed and argues that Tenn. Code Ann. § 34-1-112 supports his position.”
— Tenn. Code Ann. § 34-1-112(a) — 1 case
In Re Conservatorship of Betty A. Winston (Tenn. Ct. App. 2026). “” Tenn. Code Ann. § 34-1-112 (c). After hearing Appellant’s testimony, the trial court ruled that Appellant “breached her fiduciary relationship as to some expenditures because such were not expenditures for the benefit or protection of [Ward], or were compensation without prior…”
— Tenn. Code Ann. § 34-1-112(c) — 1 case
In Re Conservatorship of Betty A. Winston (Tenn. Ct. App. 2026). “” Tenn. Code Ann. § 34-1-112 (c). After hearing Appellant’s testimony, the trial court ruled that Appellant “breached her fiduciary relationship as to some expenditures because such were not expenditures for the benefit or protection of [Ward], or were compensation without prior…”
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