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DROBNY v. C.I.R.

No. 95-2966.

113 F.3d 670 (1997)

Sheldon DROBNY and Anita Drobny, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided May 1, 1997.

Rehearing and Suggestion for Rehearing Denied June 5, 1997.

Attorney(s) appearing for the Case

Sheldon Drobny, argued, Northbrook, IL, pro se.

Anita Drobny, Northbrook, IL, pro se.

Gary R. Allen, Kenneth L. Greene, Janet Bradley, argued, Dept. of Justice, Tax Div., Appellate Section, Washington, DC, for Respondent-Appellee.

Before COFFEY, MANION and KANNE, Circuit Judges.

Rehearing and Suggestion for Rehearing En Banc Denied June 5, 1997.

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...

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