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III. Did Decedent Substantially Comply?
A. Substantial Compliance Doctrine
Petitioner argues, despite decedent's failure to comply
with the literal requirements of section 2518, that decedent
nonetheless substantially complied with section 2518 because he
intended to disclaim the assets at issue, accurately described
the assets to be disclaimed in the Documents, and delivered the
Documents to himself as personal representative. The doctrine of
substantial compliance has its origins in equity and is designed
to avoid hardship in cases where a party does all that can
reasonably be expected of him, but he nonetheless has failed to
comply with the requirements of a statutory provision. See
Sawyer v. County of Sonoma, 719 F.2d 1001 (9th Cir. 1983).
This Court has applied the substantial compliance doctrine
and excused taxpayers from strict compliance with procedural
regulatory requirements, provided that the taxpayer substantially
complied by fulfilling the essential statutory purpose. See,
e.g., American Air Filter Co. v. Commissioner, 81 T.C. 709, 720
(1983); Tipps v. Commissioner, 74 T.C. 458, 468 (1980); Taylor v.
Commissioner, 67 T.C. 1071 (1977); Hewlett-Packard Co. v.
Commissioner, 67 T.C. 736, 748 (1977); Sperapani v. Commissioner,
42 T.C. 308, 330-333 (1964). Most cases in which we have applied
the doctrine of substantial compliance were alleged failures to
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