Tennessee Code Annotated
Tenn. Code Ann. § 67-1-1807 (2026)
Applicable laws - Conditions precedent for recovery - Conflicting laws
✓ current as of May 2026
- (a) All taxes paid on or after January 1, 1986, shall be governed by the laws regarding refunds and suits for the recovery of taxes as set out in this part.
- (b)
- (1) It shall not be a condition precedent for suit for recovery of taxes paid on or after January 1, 1986, that the taxes be paid under protest, involuntarily, or under duress.
- (2) No suit for the recovery of any tax paid prior to January 1, 1986, shall be allowed unless such tax was paid under protest.
- (c) To the extent that this section conflicts with any other law, this section shall control and supersede all such laws.
Acts 1986, ch. 749, § 11; 1987, ch. 92, § 1.
Notes of Decisions
Cited in 8
cases, 1991–2018 · leading case: Chuck's Package Store v. City of Morristown, 545 S.W.3d 398 (Tenn. 2018).
Chuck's Package Store v. City of Morristown, 545 S.W.3d 398 (Tenn. 2018). “See Tenn. Code Ann. § 67-1-1807 (b)(2) ; Aluminum Co.”
Comdata Network, Inc. v. State Dep't of Revenue, 852 S.W.2d 223 (Tenn. 1993). “The taxpayer contends that its “credit carryover claim was approved” and “the subsequent attempt by the Department of Revenue to revoke approval” constituted “payment” within the meaning of T.C.A. § 67-1-1807. The determinative issue then is whether the claim is for “taxes paid…”
Chuck's Package Store v. City of Morristown (Tenn. Ct. App. 2016). “” The trial court held that Tenn. Code Ann. § 67-1-1807 (2013) relieved the plaintiffs of the requirement to pay the inspection fees under protest.”
Adm. Suites & Inns, LLC v. Shelby Cnty., Tennessee, 138 S.W.3d 233 (Tenn. Ct. App. 2003). “§ 67-1-1807 (2003) relieves the obligation to pay “under protest” before pursuing a claim against the governmental entity imposing the tax.”
Wicker v. Comm'r, 342 S.W.3d 35 (Tenn. Ct. App. 2010). “§ 67-1-1807(c). Therefore, we must consider whether the Taxpayer Remedies Statute authorizes a class action.”
Decatur Cnty. v. Vulcan Materials (Tenn. Ct. App. 2002). “The mineral companies rely on section 67-1-1807 of Tennessee Code Annotated, which states: (d)(1) It shall not be a condition precedent for suit for recovery of taxes paid on or after January 1, 1986, that the same be paid under protest, involuntarily, or under duress.”
Gen. Motors Corp. v. Taylor, 811 S.W.2d 897 (Tenn. 1991). “” Resolution of the case is dependent upon the meaning of the following pertinent portions of T.C.A. § 67-1-1807: Applicable laws — Conditions precedent for recovery — Conflicting laws.”
Adm. Suites & Inns, Llc v. Shelby Cnty. (Tenn. Ct. App. 2003). “In that case, we recognized that Tenn. Code Ann. § 67-1-1807 (2003) relieves the obligation to pay “under protest” before pursuing a claim against the governmental entity imposing the tax.”
— Tenn. Code Ann. § 67-1-1807(a) — 1 case
Chuck's Package Store v. City of Morristown, 545 S.W.3d 398 (Tenn. 2018). “See Tenn. Code Ann. § 67-1-1807 (b)(2) ; Aluminum Co.”
— Tenn. Code Ann. § 67-1-1807(b) — 1 case
Chuck's Package Store v. City of Morristown, 545 S.W.3d 398 (Tenn. 2018). “See Tenn. Code Ann. § 67-1-1807 (b)(2) ; Aluminum Co.”
— Tenn. Code Ann. § 67-1-1807(b)(1) — 1 case
Chuck's Package Store v. City of Morristown, 545 S.W.3d 398 (Tenn. 2018). “See Tenn. Code Ann. § 67-1-1807 (b)(2) ; Aluminum Co.”
— Tenn. Code Ann. § 67-1-1807(c) — 2 cases
Chuck's Package Store v. City of Morristown, 545 S.W.3d 398 (Tenn. 2018). “See Tenn. Code Ann. § 67-1-1807 (b)(2) ; Aluminum Co.”
Wicker v. Comm'r, 342 S.W.3d 35 (Tenn. Ct. App. 2010). “§ 67-1-1807(c). Therefore, we must consider whether the Taxpayer Remedies Statute authorizes a class action.”
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