On January 6, 2020, the Tax Court issued a Memorandum Opinion in the case of Chicago Baseball Holdings LLC v. Commissioner (T.C. Memo. 2020-2). The issue presented in Chicago Baseball Holdings LLC v. Commissioner was whether prior written supervisory approval of penalties was required before the IRS communicates the penalties to the taxpayer for the first time, even if such communication was informal. Jurisdiction in Chicago Baseball Holdings LLC v. Commissioner The Tax Court has jurisdiction