(2) As used in this section:
(a) A taxpayer’s position is "frivolous" if there was no objectively reasonable basis for asserting the position.
(b) "Position" means any claim, defense or argument asserted by a taxpayer without regard to any other claim, defense or argument asserted by the taxpayer. [1987 c.843 §4; 1995 c.650 §6a; 2009 c.640 §5]