In case you were wondering...

In Rev. Proc. 2001-41 (IRB 2001-33) the IRS modified Rev. Proc. 2001-2 to clarify that it will not issue technical advice on frivolous issues. For purposes of this program, a "frivolous issue" is one without basis in fact or law, or that espouses a position which has been held by the courts to be frivolous or groundless.