Tennessee Code Title 67. Taxes and Licenses § 67-8-103

(a) The tax provided for in this part shall be computed upon net gifts made during the calendar year.

(b) For the purposes of this part, “net gifts” means the total amount of gifts made during such year, less the value of all property transferred to the United States, the state of Tennessee, or to any political subdivision thereof, any public institution therein for exclusively public purposes, or any corporation, society, association or trust therein, or in a state that grants a like exemption to such institutions in Tennessee, formed for charitable, educational, scientific, or religious purposes; provided, that the property so transferred is to be used exclusively for one (1) or more of such purposes.

(c) No deduction shall be allowed on account of property transferred to any such beneficiary, if any officer, member, shareholder or employee thereof shall receive, or be entitled to receive, any benefit or pecuniary profit from the operation thereof, except reasonable compensation in effecting one (1) or more of such purposes, or as beneficiaries of a strictly charitable purpose; or if the organization of any such corporation, society, association, or trust for any of the foregoing avowed purposes be a mere guise or pretense for directly or indirectly making for it or any of its officers, members, shareholders or employees any other pecuniary profit; or if it be not in good faith organized or conducted for one (1) or more of such purposes.