Tenn. Code Ann. § 67-8-410

When any executor, administrator or trustee shall neglect or refuse to file the return, the commissioner is authorized to appraise the estate and to assess the tax upon the basis of all information available. Notice of such appraisal and tax assessment shall be given by the commissioner in accordance with § 67-8-409(e) and (f), and the procedure thereafter with reference to an appeal from the appraisal and with reference to the collection of the tax shall be the same as in other cases.