Tenn. Code Ann. § 67-8-115: [Not applicable to any transfer by gift made on or after January 1, 2012, see 67-8-118.] Liability of donee

If the tax imposed under this part is not paid by the donor when due, and if a distress warrant directed against the property of such donor has been returned nulla bona, the donee of any gift shall be personally liable for such tax to the extent of the value of such gift.