circuits and within the Court of Federal Claims itself regarding the issue”). In its November 9, 2007 opinion and order, the court determined that the six-year extended statute of limitations of I.R.C. § 6501(e)(1)(A) would apply, because an omission from gross income may occur in the overstatement of basis, and plaintiffs could not invoke the gross receipts or adequate disclosure provisions. A split within the Court of Federal Claims exists as to how the United States Supreme Court’s holding in Colony, Inc. v. Commissioner, 357 U.S. 28, 78 S.Ct. 1033, 2 L.Ed.2d 1119 (1958), applies to the interpretation of I.R.C. § 6501(e)(1)(A) and whether an overstatement of basis may constitute an omission from gross income. Compare Grapevine Imports, Ltd. v. United States, 77 Fed.Cl. 505 (2007) (<HOLDING>), with Salman Ranch, Ltd., 79 Fed.Cl. 189
holding sixyear statute of limitations applies to adea actions involving federal employees holding the sixyear limitations period begins to run upon date that payment is made holding sixyear extended limitations period of irc  6501e1a inapplicable to partnerships overstatement of basis holding that this courts sixyear statute of limitations is jurisdictional recognizing a sixyear statute of limitations on claims filed under the coal act