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petitioner was asked to complete and submit by the date of the
meeting. The meeting was postponed until August 18, 2003, and
petitioner was given an extension until then to submit the
questionnaire and offer form. Petitioner did not complete the
questionnaire by the time of the postponed meeting, nor did he
submit the offer form at that meeting. Mr. O’Shea again extended
the time for completion of the questionnaire and submission of
the offer form, establishing a deadline of September 2, 2003, and
telling Mr. Burke that no further extension of time would be
granted. Not only did petitioner fail to meet that deadline, but
neither petitioner nor Mr. Burke contacted Mr. O’Shea to explain
any circumstance of delay or to request an extension of the
deadline.
Petitioner does not argue that Mr. O’Shea was without
discretion to set a deadline, only that he abused his discretion
by setting the deadline too soon. We disagree. Mr. O’Shea’s
establishment of a deadline of September 2, 2003, to complete the
questionnaire and the offer form was not unreasonable in light of
the facts that petitioner: (1) submitted the Form 12153 in
November 2002, (2) had from July 23, 2003 (the date Mr. O’Shea
provided him with the questionnaire and the offer form), until
September 2, 2003, to complete those documents, and (3) had
experience with offers in compromise, which, previously, he had
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