They can be done in TAO, in theory. Making it actually work is a tremendous pain in the ass. Basically you have to have an absolutely perfect cuesheet (at least for Super CD games, not sure that normal CD-ROM2 games are quite as picky) or you will end up with some kind of problem.
Just curious, why not burn in SAO mode? For a single-session disc, that should be equivalent to burning in DAO mode ...