Tennessee Code Title 67. Taxes and Licenses § 67-8-116

(a) If, in the determination of the existence of a deficiency, the commissioner appraises property at a value higher than that thought by the donor to be its true value, the donor shall have a right to file with the commissioner, within ninety (90) days from the date of the receipt of the notice of deficiency, an appeal from such appraisal, addressed to a board composed of the governor, the state treasurer, the secretary of state, the comptroller of the treasury and the commissioner, which board shall have authority to consider the exceptions filed, hear proof and determine the valuations in dispute, and the findings by a majority vote of the board shall be conclusive as to all parties in interest, subject only to the constitutional right of review in the courts.

(b) The procedure established by this section for review of the appraisal of the commissioner by the designated board shall apply only if the issue of valuation of the gift is the only objection to be raised to the assessment. If this procedure for review is selected by the donor, no challenge to any legal issues that might be raised concerning the gift tax assessment shall be entertained in any court or forum. In all cases in which the donor seeks to challenge an assessment under this section on any ground other than valuation, the entire proceeding, including issues of valuation, must be brought in accordance with §§ 67-1-1801 and 67-1-1802.

(c) In order for any person who seeks review of an appraisal by the designated board to obtain a stay of proceedings or action for the collection of the assessed tax, the person must file a complaint in chancery court seeking a stay until final determination of the review by the designated board, with a copy of the petition for review by the board attached, and must do those things necessary to obtain a stay under § 67-1-1801.