types of income. But we need not resolve this issue.” (citations omitted)); Phinney v. Chambers, 392 F.2d 680, 685 (5th Cir.1968) ("We conclude that the enactment of subsection (ii) as a part of [§ ] 6501(e)(1)(A) makes it apparent that the six year statute is intended to apply where there is either a complete omission of an item of income of the requisite amount or misstating of the nature of an item of income which places the 'commissioner ... at a special disadvantage in detecting errors.’ ” (quoting Colony, 357 U.S. at 36, 78 S.Ct. 1033)). District courts, the Court of Federal Claims, and the Tax Court have arrived at different conclusions as to the applicability of Colony to § 6501(e)(1)(A). Compare Home Concrete & Supply LLC v. United States, 599 F.Supp.2d 678, 687 (E.D.N.C.2008) (<HOLDING>); Brandon Ridge Partners v. United States, 100
holding gross receipts provision provides exception for trade or business to general meaning of gross income provided in section 61a so reporting of gross proceeds alone from sales of commodities would not prevent application of irc  6501e1a holding that punitive damages are excludable from gross income under 26 usc  104a2 holding that gross income can include interest or dividends accruing to fathers ira holding that a state is not a person within the meaning of  1983 holding that an overstatement of basis can constitute an omission from gross income within the meaning of irc  6501e1a