Tennessee Code Annotated

Tenn. Code Ann. § 66-22-114 (2026)

Certificate of acknowledgment form

✓ current as of May 2026
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Acts 1986, ch. 717, § 2; 1987, ch. 125, §§ 1, 2.


Notes of Decisions
Cited in 6 cases, 1990–2007 · leading case: In Re Akins, 87 S.W.3d 488 (Tenn. 2002).
In Re Akins, 87 S.W.3d 488 (Tenn. 2002). · cites it 26× “Section 66-22-114(a), which contains an alternative “universal” *492 form of certificate of acknowledgment, states: If the acknowledgment be made before any of the officers who are authorized to take such acknowledgment under the provisions of this chapter or any consular…”
In Re Bushee, 319 B.R. 542 (Bankr. E.D. Tenn. 2004). · cites it 14× “Tenn. Code Ann. § 66-22-114 (2004). In line with the substantial compliance test of section 66-22-114(b), the General Assembly has reiterated the following premise: Omission of words from certificate.”
D.T. McCall & Sons v. Seagraves, 796 S.W.2d 457 (Tenn. Ct. App. 1990). · cites it 6× “Thus, we have determined that Tenn. Code Ann. § 66-22-114 (b) cannot be used to supply the missing language showing that Mr.”
In Re: Ronald Lebron Akins, Sr. (Tenn. 2002). · cites it 30× “Section 66-22-114(a), which contains an alternative “universal” form of certificate of acknowledgment, states: If the acknowledgment be made before any of the officers who are authorized to take such acknowledgment under the provisions of this chapter or any consular officer of…”
Mostoller v. Equity One, Inc. (In Re Hickman), 367 B.R. 620 (Bankr. E.D. Tenn. 2007). · cites it 4× “Tenn.Code Ann. § 66-22-114(b) (2004). 6 .”
Gregory v. Ocwen Fed Bank (6th Cir. 2004). “legislature has provided statutory forms that fulfill the acknowledgment requirement, and all of the forms require the Tenn. Code Ann. § 66-22-114 (b) (emphasis added).”
Tenn. Code Ann. § 66-22-114(a): 2 cases
In Re Akins, 87 S.W.3d 488 (Tenn. 2002). “Section 66-22-114(a), which contains an alternative “universal” *492 form of certificate of acknowledgment, states: If the acknowledgment be made before any of the officers who are authorized to take such acknowledgment under the provisions of this chapter or any consular…”
In Re: Ronald Lebron Akins, Sr. (Tenn. 2002). “Section 66-22-114(a), which contains an alternative “universal” form of certificate of acknowledgment, states: If the acknowledgment be made before any of the officers who are authorized to take such acknowledgment under the provisions of this chapter or any consular officer of…”
Tenn. Code Ann. § 66-22-114(b): 5 cases
In Re Akins, 87 S.W.3d 488 (Tenn. 2002). “Section 66-22-114(a), which contains an alternative “universal” *492 form of certificate of acknowledgment, states: If the acknowledgment be made before any of the officers who are authorized to take such acknowledgment under the provisions of this chapter or any consular…”
In Re Bushee, 319 B.R. 542 (Bankr. E.D. Tenn. 2004). “Tenn. Code Ann. § 66-22-114 (2004). In line with the substantial compliance test of section 66-22-114(b), the General Assembly has reiterated the following premise: Omission of words from certificate.”
D.T. McCall & Sons v. Seagraves, 796 S.W.2d 457 (Tenn. Ct. App. 1990). “Thus, we have determined that Tenn. Code Ann. § 66-22-114 (b) cannot be used to supply the missing language showing that Mr.”
In Re: Ronald Lebron Akins, Sr. (Tenn. 2002). “Section 66-22-114(a), which contains an alternative “universal” form of certificate of acknowledgment, states: If the acknowledgment be made before any of the officers who are authorized to take such acknowledgment under the provisions of this chapter or any consular officer of…”
Mostoller v. Equity One, Inc. (In Re Hickman), 367 B.R. 620 (Bankr. E.D. Tenn. 2007). “Tenn.Code Ann. § 66-22-114(b) (2004). 6 .”
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