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obtain a waiver in order to claim credits for fuel taxes. The
authoritative sources of tax law, however, are statutes,
regulations, and judicial decisions, and not instructions
published by the Internal Revenue Service. See Sherwin-Williams
Co. Employee Health Plan Trust v. Commissioner, 115 T.C. 440, 451
(2000); Casa de La Jolla Park, Inc. v. Commissioner, 94 T.C. 384,
396 (1990).
Although petitioner may not rely merely on the printed
instructions on Form 4136, the question emerges whether petitioner
substantially complied with the requirements of the applicable
regulation such that it should not be held to strict adherence
with all regulatory requirements. 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 Bond v. Commissioner, 100 T.C. 32 (1993);
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). Substantial compliance, however,
cannot relieve a taxpayer of strict adherence if the statutory or
regulatory requirements relate to the substance or essence of the
statute. See Bond v. Commissioner, supra at 41; Sperapani v.
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