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"always" and "never" are difficult to justify when referring to bullet performance.
Like I said, I've shot several deer with 165 BT from my old 30/06. At this point, I've not found reason to complain about penetration at any distance from 40-400 yards even on shoulder shots. There WILL be significant meat damage in my experience.
On the subject of shoulder shots: this is a viable option unless you're using a pip-squeak round. Some places I hunt I need the deer down right there. Sometimes a big buck doesn't offer the picture book broadside presentation. Either of these plus numerous other scenarios justify the loss of some shoulder meat to ensure killing the animal quickly and/or assuring simpler/easier retrieval.
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