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that point. Ms. Boudreau advised Mr. Burke that, unless
petitioner disclosed the circumstances of his illness, she would
be unable to consider the illness. Mr. Burke said that he
understood and had told his client that already. Among other
things, Mr. Burke did tell Ms. Boudreau that petitioner was an
insurance salesman, owed money on credit cards, owed about
$90,000 to the Commonwealth of Massachusetts, and was divorced,
with his ex-wife receiving residual payments from insurance
contracts that petitioner had sold.
Ms. Boudreau concluded the October 3 meeting by requesting
that petitioner submit by October 31, 2002, additional
information and documents necessary for her to review the offer
in compromise. Petitioner missed that due date. Indeed,
following the October 3 meeting, and through February 10, 2003,
petitioner repeatedly missed due dates that either Ms. Boudreau
or Mr. Burke himself had set for submitting information necessary
for Ms. Boudreau to review the offer in compromise. On one
occasion during that period, due to petitioner’s failure to meet
submission due dates, Ms. Boudreau closed petitioner’s case and
concluded that she should sustain the proposed levy action. She
decided to reopen the case only after petitioner belatedly
complied with a request for certain information.
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