On January 6, 2020, the Tax Court issued its opinion in Belair Woods LLC v. Commissioner (154 T.C. No. 1). The issue presented in Belair Woods LLC v. Commissioner was when, precisely, was written supervisory approval required pursuant to IRC § 6751(b)(1) (initial determination of penalty assessment). The penalties at issue in Belair Woods were gross overvaluation (IRC § 6662(h)), negligence (IRC § 6662(c)), and substantial understatement (IRC § 6662(d)). Written Supervisory Approval (IRC § 6751(b)(1)