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Instead of using H1, H2, H3 many use a P tag with a gosh-awful CSS class call out.
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H* tags always trigger a page-break-before on the Kindle. That's not always desirable. Like chapter numbers with a (same-sized) chapter name beneath it. Nobody wants a pagebreak in between those two items, so they use a P tag with CSS to simulate a header.
I
wish chapter headers were more consistently tagged, but I also understand why they're oftentimes not.