(1) The commissioner has the discretion, on the basis of adequate past experience, to recall any certificate of registration where, in the commissioner's judgment, the cost of administering the account is disproportionately high as compared to the amount of tax that a taxpayer is remitting or will remit.
(2) Such recall shall be reviewable by a petition for a common law writ of certiorari in the chancery court of Davidson County, which petition shall be filed within ten (10) days from the date of such recall.