It's the third recommended target in the event that you stumble upon a deer that lacks a trunk area, and is running around on legs and feet which are growing out of its skull. I've gone hunting probably a couple hundred times, and I've never once shot a deer in the head. Nor have I seen anyone else shoot a deer in the head. Not on purpose. At range its very inefficient. I've seen a few neck shots, but those were accidental and fairly grotesque. It's not a kind way to make an animal die. Aside from the tail the head is the part of animal that moves the most, it's a small target, the brain within the skull is even smaller, and the junctions between the racks and the skull are nice and thick. So while you're busy blowing off cheeks, bits of antler, and nasal cavities, you could just put a round through all of its vitals instead. *shrug*
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