Sheldon Drobny and Anita Drobny v. Commissioner of Internal Revenue
Court of Appeals for the Seventh Circuit
1Opinion of the Court
COFFEY, Circuit Judge.
The petitioners-appellants, Sheldon and Anita Drobny, are husband and wife. During the late 1970’s, Sheldon Drobny, a former IRS agent, was a partner in the accounting firm of Adler & Drobny, Ltd., based near Chicago, Illinois. Drobny promoted (and he and his wife invested in) two “research and development” programs purportedly designed to develop the substance known as “aloe vera” for commercial purposes. “Aloe vera” is an extract of the Aloe Barbadensis plant, and today is used in many skin-care and personal hygiene products. The Drobnys, on their joint federal income…
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