If an opponent has an extremely tight raising range from a certain position or just in general, then calling out of position with hands like KTo and QTo may not be a part of a good game plan. The positive externalities of future bets you induce, or pots you are able to take away by representing wider ranges for value, may not be enough to offset the reverse implied odds of the situation. In other words, the idea of our pre-flop hand selection goes back to dominating hands. If we are always dominated or even often dominated in a spot, folding and sometimes three-betting the hand pre-flop may be the best way to play the hand against a particular opponent. The best way to avoid tough spots is to avoid putting yourself into the situation where they will often occur. However, it's important to distinguish between a tough spot and a non-profitable spot. Sometimes, a spot will foster so many difficult decisions against a well-playing opponent that the expected value of the situation will plumet because our opponent will use position to outplay us, making sure we win the minimum and lose the maximum at all the right times. Difficult spots don't always mean money-losing spots; however, the two often go along with each other because the more mistakes someone makes in poker, the more money they will lose. Large and difficult decisions with a semi-face up range on the river after checking and calling flop and turn is a fairly common example of the quintessential "tough spot" in No-Limit Hold'em. Without position, our opposition controls the frequencies of betting as the board changes and so it's very difficult to play well versus someone who has a solid read of your range and who is able to exploit that read by three-barrelling and over-betting effectively, by which I mean your opponent will bet in a way that induces you to make a mistake by either calling or folding too often.