Tennessee Code Annotated
Tenn. Code Ann. § 67-1-1804 (2026)
Exclusivity of procedures
✓ current as of May 2026
The procedure established by this part is the sole and exclusive jurisdiction for determining liability for all taxes collected or administered by the commissioner of revenue, except that the state board of equalization shall have jurisdiction concurrent with the chancery court in inheritance tax cases in which only issues of valuation are raised, as provided by § 67-8-411, and the board designated in § 67-8-116 shall have jurisdiction concurrent with the chancery court in gift tax cases in which only issues of valuation are raised, as provided by § 67-8-116.
Acts 1986, ch. 749, § 8.
Notes of Decisions
Cited in 15
cases (3 in the last 5 years), 1991–2024 · leading case: L.L. Bean, Inc. v. Bracey, 817 S.W.2d 292 (Tenn. 1991).
L.L. Bean, Inc. v. Bracey, 817 S.W.2d 292 (Tenn. 1991). “The chancellor held that Tennessee affords such a remedy in state tax cases and that the procedure is declared by T.C.A. § 67-1-1804 to be the exclusive remedy under state law.”
Colonial Pipeline Co. v. Morgan, 263 S.W.3d 827 (Tenn. 2008). “The opinion prohibited the Chancery Court from issuing a declaratory judgment regarding the constitutionality of “a statute dealing with state tax revenue if such exercise of jurisdiction would .”
James T. (Tom) Higdon v. State of Tennessee, 404 S.W.3d 478 (Tenn. Ct. App. 2013). “See Tenn.Code Ann. § 67-1-1804. Plaintiffs complaint is not properly before this Court as an assessment challenge because it was not “[fjiled within ninety (90) days from the date of the mailing of the notice of assessment to the taxpayer by the commissioner.”
Bloomingdale's by Mail Ltd. v. Huddleston, 848 S.W.2d 52 (Tenn. 1992). “To do otherwise would undermine the exclusive authority provided in T.C.A. § 67-1-1804 for determining liability with respect to taxes collected or administered by the Department of Revenue.”
Wicker v. Comm'r, 342 S.W.3d 35 (Tenn. Ct. App. 2010). “is empowered and directed to refund to taxpayers all taxes collected or administered by the commissioner that are, on the date of payment, paid in error paid against any statute, rule, regulation or clause of the constitution of this state or of the United States.”
Zimmer US, Inc. v. David Gerregano (Tenn. Ct. App. 2021). “Further, because Tennessee’s Taxpayer Remedies Statutes, Tenn. Code Ann. § 67-1-1801 to -1808, provides “the sole and exclusive jurisdiction for determining liability for all taxes collected or administered by the commissioner of revenue,” Tenn.”
Chuck's Package Store v. City of Morristown (Tenn. Ct. App. 2016). “” Tenn. Code Ann. § 67-1-1804 . The plaintiffs point out that Tenn.”
AT&T Mobility II, LLC v. Richard H. Roberts, Comm'r of Revenue, State of Tennessee (Tenn. Ct. App. 2016). “2013) (quoting Tenn. Code Ann. § 67-1-1804 (2011)). The underlying matter does not involve an incorrect assessment of taxes; rather, it involves a claim for a refund for sales taxes mistakenly collected by AT&T in contravention of federal and Tennessee law4 and paid to the…”
Roy Zumstein v. Roane Cnty. Exec./Mayor, Assessor Of Prop., Tr. (Tenn. Ct. App. 2017). “]” Tenn. Code Ann. § 67-1-1804 (emphasis added).”
Stargate Auto Sales, LLC v. David Gerregano, Comm'r of the Tennessee Dep't of Revenue (Tenn. Ct. App. 2024). “” Stargate’s complaint was brought under Tenn. Code Ann. § 67-1-1801 , which governs the manner and procedure for bringing suit against the state when a party believes the final assessment of tax owed is “unjust, illegal or incorrect.”
Cherokee Fiber & Assocs. , Inc. v. David Gerregano, Comm'r of the Tennessee Dep't of Revenue (Tenn. Ct. App. 2024). “” Cherokee’s complaint was brought under Tenn. Code Ann. § 67-1-1801 , which governs the manner and procedure for filing suit against the state when a party believes the final assessment of tax owed is “unjust, illegal or incorrect.”
James W. Swafford, Jr. v. Comm'r of Revenue (Tenn. Ct. App. 2012). “” Tenn. Code Ann. § 67-1-1804 (2011). This exclusivity also applies to claims for refunds made on constitutional grounds.”
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