Tennessee Code Annotated

Tenn. Code Ann. § 67-5-2010 (2026)

Interest - Delinquent taxes

✓ current as of May 2026
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Amended by 2022 Tenn. Acts, ch. 900, s 13, eff. 7/1/2022.

Amended by 2017 Tenn. Acts, ch. 299, s 4, eff. 7/1/2017.

Amended by 2014 Tenn. Acts, ch. 883, s 4, eff. 7/1/2014.

Amended by 2013 Tenn. Acts, ch. 370, s 1, eff. 5/14/2013.

Acts 1988, ch. 526, § 6.


Notes of Decisions
Cited in 13 cases, 1991–2017 · leading case: In Re Gift, 469 B.R. 800 (Bankr. M.D. Tenn. 2012).
In Re Gift, 469 B.R. 800 (Bankr. M.D. Tenn. 2012). · cites it 22× “§ 511 , and Tenn.Code Ann. § 67-5-2010 (“T.C.A.”). The debtor ar *802 gues that only the 12% interest rate should be applied.”
In re Bratt, 527 B.R. 303 (Bankr. M.D. Tenn. 2015). · cites it 42× “In that case, the Metropolitan Government of Nashville and Davidson County (“Metro”) sought to be paid on its oversecured claim for delinquent property taxes through the debtor’s Chapter 13 plan, including a 6% penalty pursuant to T.C.A. § 67-5-2010. The Gift decision stated…”
State of Tenn. v. Michael Corrin, 849 F.3d 653 (6th Cir. 2017). · cites it 7× “Tenn. Code Ann. § 67-5-2010 . In 2012, a Tennessee bankruptcy court held that only the post-petition interest and not the penalty portion could be collected for oversecured claims in bankruptcy proceedings.”
In re Bratt, 549 B.R. 462 (6th Cir. BAP 2016). · cites it 12× “5%) and interest of one percent (1%) shall be added on March 1, following the tax due date and on the first day of each succeeding month, except as otherwise provided in regard to municipal taxes____ Tenn. Code Ann. § 67-5-2010 (a)(l). Metro objected to plan confirmation…”
United States v. George Marcus Hall, 877 F.3d 676 (6th Cir. 2017). · cites it 2× “§ 67-5-2410 (imposing what appears to be a one-time penalty upon the filing of a tax suit, which Knox County either has or has not already initiated), the current version of Tennessee’s tax code calls for interest to accrue monthly on delinquent taxes, see Tenn. Code Ann. §…”
In Re Goody's Fam. Clothing, Inc., 443 B.R. 5 (Bankr. D. Del. 2010). · cites it 3× “09-10124] 2/28/09 Last day before 2008 Taxes are delinquent under Tenn.Code Ann. § 67-5-2010(a)(1) 3/1/09 Penalty begins to accrue on unpaid 2008 Taxes under Tenn.”
In Re Brentwood Outpatient Ltd., 134 B.R. 267 (Bankr. M.D. Tenn. 1991). “§ 67-5-2010 (1989) provides: Penalty and interest.”
S. Ry. Co. v. Stair, 801 F. Supp. 37 (W.D. Tenn. 1992). · cites it 2× “Defendants contend that the penalty provided by T.C.A. § 67-5-2010 is mandatory and the statute does not permit waiver or abatement of the penalty.”
In re: Mildred Bratt v. (6th Cir. BAP 2016). · cites it 12× “Tenn. Code Ann. § 67-5-2010 (a)(1). Metro objected to plan confirmation asserting that the proper interest rate under Tennessee law is 18%.”
Bondholder Comm. v. Williamson Cnty. (In re Brentwood Outpatient, Ltd.), 43 F.3d 256 (6th Cir. 1994). “shall be added on March 1, following the tax due date and on the first day of each succeeding month[.”
In Re D.M. White Constr. Co., 366 B.R. 820 (Bankr. E.D. Tenn. 2007). · cites it 2× “Instead, the trustee objects to Hamilton County’s calculation of interest on the claims at a rate of 12% rather than the 6% prime rate which was in effect at the time of filing the petition, and asserts that § 506(b) requires a “reasonable” interest rate in fairness to the other…”
State of Tennessee for the use & benefit of Williamson Cnty. v. Jesus Christ's Church @ Liberty Church Road (Tenn. Ct. App. 2011). · cites it 2× “5 Penalty and interest are incurred on delinquent taxes pursuant to Tenn. Code Ann. § 67-5-2010 ; once suit to enforce a tax lien is filed, additional penalties, fees and costs accrue in accordance with Tenn.”
— Tenn. Code Ann. § 67-5-2010(a) — 1 case
In re Bratt, 527 B.R. 303 (Bankr. M.D. Tenn. 2015). “In that case, the Metropolitan Government of Nashville and Davidson County (“Metro”) sought to be paid on its oversecured claim for delinquent property taxes through the debtor’s Chapter 13 plan, including a 6% penalty pursuant to T.C.A. § 67-5-2010. The Gift decision stated…”
— Tenn. Code Ann. § 67-5-2010(a)(1) — 2 cases
In Re Goody's Fam. Clothing, Inc., 443 B.R. 5 (Bankr. D. Del. 2010). “09-10124] 2/28/09 Last day before 2008 Taxes are delinquent under Tenn.Code Ann. § 67-5-2010(a)(1) 3/1/09 Penalty begins to accrue on unpaid 2008 Taxes under Tenn.”
In re: Mildred Bratt v. (6th Cir. BAP 2016). “Tenn. Code Ann. § 67-5-2010 (a)(1). Metro objected to plan confirmation asserting that the proper interest rate under Tennessee law is 18%.”
— Tenn. Code Ann. § 67-5-2010(a)(l) — 2 cases
In re Bratt, 549 B.R. 462 (6th Cir. BAP 2016). “5%) and interest of one percent (1%) shall be added on March 1, following the tax due date and on the first day of each succeeding month, except as otherwise provided in regard to municipal taxes____ Tenn. Code Ann. § 67-5-2010 (a)(l). Metro objected to plan confirmation…”
In Re Goody's Fam. Clothing, Inc., 443 B.R. 5 (Bankr. D. Del. 2010). “09-10124] 2/28/09 Last day before 2008 Taxes are delinquent under Tenn.Code Ann. § 67-5-2010(a)(1) 3/1/09 Penalty begins to accrue on unpaid 2008 Taxes under Tenn.”
— Tenn. Code Ann. § 67-5-2010(d) — 3 cases
In re Bratt, 527 B.R. 303 (Bankr. M.D. Tenn. 2015). “In that case, the Metropolitan Government of Nashville and Davidson County (“Metro”) sought to be paid on its oversecured claim for delinquent property taxes through the debtor’s Chapter 13 plan, including a 6% penalty pursuant to T.C.A. § 67-5-2010. The Gift decision stated…”
In re Bratt, 549 B.R. 462 (6th Cir. BAP 2016). “5%) and interest of one percent (1%) shall be added on March 1, following the tax due date and on the first day of each succeeding month, except as otherwise provided in regard to municipal taxes____ Tenn. Code Ann. § 67-5-2010 (a)(l). Metro objected to plan confirmation…”
In re: Mildred Bratt v. (6th Cir. BAP 2016). “Tenn. Code Ann. § 67-5-2010 (a)(1). Metro objected to plan confirmation asserting that the proper interest rate under Tennessee law is 18%.”
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