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prerequisite to seeking relief under the substantial compliance
doctrine is a showing that the taxpayer wished to avail himself
of a certain tax treatment and attempted to comply with the
applicable requirements. Finally, there is no defense of
substantial compliance for failure to comply with the essential
requirements of the governing statute. See Prussner v. United
States, 896 F.2d 218, 224 (7th Cir. 1990); see also Tipps v.
Commissioner, supra at 468; Penn-Dixie Steel Corp. v.
Commissioner, 69 T.C. 837, 846 (1978); Rockwell Inn, Ltd. v.
Commissioner, T.C. Memo. 1993-158. Moreover, substantial
compliance cannot be applied if to do so would defeat the
policies of the underlying statutory provisions. See Sawyer v.
County of Sonoma, supra at 1008.
We have examined the specific requirements of section
2518(b) to determine whether they relate to the substance or
essence of the statutory and regulatory scheme. See Young v.
Commissioner, supra at 838; Tipps v. Commissioner, supra. We
have also examined the legislative history of section 2518. See,
e.g., Cary v. Commissioner, 41 T.C. 214, 218-219 (1963); Taylor
v. Commissioner, supra at 1078; see also United States v. St.
Regis Paper Co., 355 F.2d 688, 692 (2d Cir. 1966) ("If a
requirement [of a statute] is so essential a part of the plan
that the legislative intent would be frustrated by a
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