- 14 - the language or the rationale of Colony, Inc. can be limited to the sale of goods or services by a trade or business. As petitioners point out, the Supreme Court held that “omits” means something “left out” and not something put in and overstated. We apply the holding of Colony, Inc. v. Commissioner, supra, to this case and conclude that the 6-year period of limitations set forth in section 6501(e) does not apply. Thus, we need not determine whether the amounts in dispute were disclosed on the return in a manner adequate to apprise the Secretary of the nature and amount of the omitted item. Because of the stipulation that no other exception to the normal 3-year period applies to any of the individual partners and to reflect the foregoing, An order and decision will be entered granting petitioners’ motion for summary judgment and denying respondent’s motion for partial summary judgment.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14Last modified: November 10, 2007