- 9 -
Commissioner, supra at 331. In other words, the doctrine of
substantial compliance cannot be applied if to do so would defeat
the policies of the underlying statutory provisions. See Estate
of Chamberlain v. Commissioner, T.C. Memo. 1999-181.
The legislative history of section 6420 clearly reflects that
the purpose of the statute was to provide financial relief to
farmers. See S. Rept. 1609, 84th Cong., 2d Sess. (1956), 1956-1
C.B. 989. As section 6420 was originally enacted only the owner,
tenant, or operator of a farm was eligible for the fuel credit.
Pesticide applicators deliberately were excluded from the benefits
of the credit because there was no assurance that they would pass
the benefit on to farmers. See id.
Effective on April 1, 1979, section 6420(c) was amended to
allow “aerial applicators” to receive the fuel credit if the
owner, tenant, or operator of the farm consents by waiving his
right to the credit. Act of October 14, 1978, Pub. L. 95-458,
sec. 3, 92 Stat. 1257. The amendment was designed to alleviate
the burden to both aircraft operators and farmers from the system
under which the aircraft operator must supply each farm owner,
operator, or tenant with sufficient information concerning the
number of gallons of fuel consumed by the aircraft on a particular
farm. See S. Rept. 95-1127, 1978-2 C.B. 369, 371-372. The
Surface Transportation Assistance Act of 1982 expanded the
availability of the credit to ground applicators if the farm
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