INTRP. 1-1.03: "A frivolous position is one which is knowingly advanced in bad faith and is patently improper."
INTRP. 1-1.07: "In determining whether a tax return position meets the realistic possibility standard, a CPA may rely on authorities in addition to those evaluated when determining whether substantial authority exists.
INTRP. 1-1.08: "In determining whether a realistic possibility exists, the CPA should do all of the following.