A topic on another thread got me to thinking. What makes a deer, any deer, the hardest most challenging deer to kill?

And does your choice of gun or bow make it more or less of a challenge?

For me, I would answer this by saying that any deer that has had so many negative human encounters, that it has an immediate evasive response to the slightest detection of human presence, is a tough deer to kill. Especailly season after season. Buck or doe.
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