Tennessee Code Title 67. Taxes and Licenses § 67-2-115

(c)(1) If the commissioner, in determining the correct amount of the tax, determines that there is a deficiency in respect of the tax imposed by this chapter, the commissioner shall send notice of the deficiency to the taxpayer by mail and shall make demand for the amount of the deficiency, which amount shall be paid by the taxpayer.

(2) The deficiency, regardless of when paid, shall, for purposes of computing interest and penalty on the deficiency, be deemed to have been due on the due date provided in § 67-2-112, that is, the fifteenth day of the fourth month commencing after the end of the taxpayer's tax year.

(3) Notice of deficiency may be issued for the purpose of making or revising, correcting, and/or increasing assessments and/or returns or reports of persons for the year in which such notice may be issued and/or five (5) years preceding such year, but no longer or otherwise; provided, that in the case of a fraudulent return with intent to evade tax or of a failure to file a return, the statute of limitations will not apply.