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                                                                     Exhibit 5.1

                           HUNTER, SMITH & DAVIS, LLP

                              1212 N. EASTMAN ROAD

                              POST OFFICE BOX 3740

                           KINGSPORT, TENNESSEE 37664

                                  May 22, 2000

BancTenn Corp.
301 East Center Street
Kingsport, Tennessee  37660

Ladies and Gentlemen:

         We are acting as counsel to BancTenn Corp., a Tennessee corporation
(the "Company"), located in Kingsport, Tennessee. In such capacity, we have
supervised certain proceedings taken by the Company in connection with the
registration under the Securities Act of 1933, as amended, and the rules and
regulations of the Securities and Exchange Commission promulgated thereunder
(collectively, the "Act"), of the offer and sale of up to 428,571 shares (the
"Shares") of common stock, $8.00 par value, of the Company.

         We have examined originals or copies, certified or otherwise identified
to our satisfaction, of the documents and corporate records relating to the
authorization, issuance and sale of the Shares and have made such other
investigation as we have deemed appropriate and relevant in order to furnish the
opinion set forth below.

         In our examination we have assumed the genuineness of all signatures,
the authenticity of all documents submitted to us as original documents, and the
conformity to original documents of all documents submitted to us as certified
or photostatic copies. As to questions of fact material and relevant to our
opinion, where such facts were not independently verified by us, we have relied,
to the extent we deemed such reliance proper, upon certificates or
representations of officers and representatives of the Company and appropriate
federal, state and local officials.

         Based upon the foregoing, we are of the opinion that the Shares have
been duly authorized and when sold, will be validly issued, fully paid and
nonassessable.

         We hereby consent to the reference to our firm under the heading "Legal
Matters" in, and to the filing of this opinion as Exhibit 5.1 to, the
Registration Statement on Form SB-2 filed with the Securities and Exchange
Commission by the Company in connection with the offer and sale of the Shares.

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BancTenn Corp.
May 22, 2000

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         This letter is furnished solely to you and may not be relied upon by
any third party without our express prior written permission.

                                             Very truly yours,


                                             /s/ HUNTER, SMITH & DAVIS, LLP