I've read a lot of warnings about cloaking and deceiving SE's and hidden text, etc. But what if I simply position a h1 heading to be -20 from the top so it's invisible, using css? Is this cloaking and would G penalize this u think? Would the robots even identify it as hidden? I've considered giving my css directory a different name and then disallowing that to robots, so the robots can't see it's hidden.
It's not an irrelevant heading anyway, but my site layout does not allow me to have my h1 heading with keywords near my body tag.
I would say the best thing to do would be to test this on a test domain that you don't care about and analyze how the spider crawls the page. You may want to do a paid submission to get spidered quickly.
The only problem you will have is someone reporting it. Gezz I know of a site that has been using <body bgcolor="#000000"><font color="#000000">keywords</font> for years with no problem. But yes Google or any seacrh engine would most likely ban you if the came across it on a manual review.