Crop Care Applicators, Inc. - Page 10

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          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  As section 6420 was originally enacted only the owner,           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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