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to one of respondent’s witnesses testifying under a pseudonym,
but failed to file any reply to respondent’s written response to
their objection. They were more than 6 months tardy in
responding to our order of June 14, 2000, that they make a motion
to substitute parties and change caption. They requested a
briefing schedule, and the Court ordered briefs, yet their brief
fails to address the substance of respondent’s adjustments. In
their brief, they fail to make any specific reference to any page
of the transcript of trial or reference any exhibit. We infer
from their failure adequately to brief the issues in this case a
lack of legitimate purpose in instituting this proceeding. They
failed to file an answering brief, and, thus, let stand,
unrebutted, 141 proposed findings of fact made by respondent.
They established the Alexion and Caralan Trusts, which invoked,
and then disavowed, the jurisdiction of this Court.
The J. Shirleys instituted and maintained these proceedings
primarily for delay; their positions in this proceeding are
frivolous and groundless, and they unreasonably failed to pursue
administrative remedies. We, therefore, shall require them to
pay a penalty under section 6673(a)(1) of $12,500.
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