Vincent Roggio; Callie Lasch v. Commissioner of Internal Revenue On Appeal from the United States Tax Court No.…

NOT PRECEDENTIAL
UNITED STATES COURT OF APPEALS
FOR THE THIRD CIRCUIT
No. 04-2438
Vincent Roggio; Callie Lasch
Appellants
v.
Commissioner of Internal Revenue
On Appeal from the United States Tax Court
No. 0090-1
Tax Court Judge: Honorable Robert Wherry, Jr.
Submitted Pursuant to Third Circuit LAR 34.1(a)
March 8, 2005
BEFORE: NYGAARD, McKEE & RENDELL, Circuit Judges
(Filed: April 6, 2005)
OPINION
PER CURIAM.
Vincent Roggio and Callie Lasch (“Taxpayers”) appeal an Order of the United
States Tax Court in which the court concluded that the Commissioner did not abuse his
discretion in filing a lien on property owned by Taxpayers in an effort to collect a tax
liability for the tax year 2000 that was admittedly due and owing. Taxpayers argue that
their demonstrated good faith, which included entering into an installment plan to
discharge the liability, should have precluded the Commissioner from engaging in what
they refer to as “a very intrusive collection technique.” See Appellants’ brief at 5. We

-- 1 of 2 --

2
will affirm.
Inasmuch as we write only for the parties who are familiar with the background of
this case, we need not reiterate the factual or procedural history. Appellants have
submitted a brief consisting of two paragraphs of argument, without citation to any legal
authority, in which they argue that, “[i]n a credit-based society, a lien is a very intrusive
collection technique.” Id. at 5.
We have reviewed the transcript from the bench opinion of the Tax Court dated
February 9, 2004. In that opinion, the Honorable Robert Wherry, Jr., explains why the
Commissioner did not abuse his discretion in filing the lien that is the subject of this
dispute. We will affirm this frivolous appeal substantially for the reasons set forth by
Judge Wherry in his bench opinion.

-- 2 of 2 --