Be patient, I will get to your question. This is an ongoing issue regarding the height/size, or scale of a figure. By no means do I have, or claim to be an authority, or have the universal one true answer. The subject seemed to really dust up with the release of Conte's ACW figures, and then really got going with TSSD's line of figures. Both resisting comments, and complaints that their figures were bigger, more 60mm, and out of scale to/for legacy figure lines. Saying the new stuff was not 54mm/1/32. Conte, and TSSD fought back, saying "The figures are more 3D, this is why they look bigger, or with TSSD position, it was their bigger, detailed bases that gave the appearance that the figures were bigger. Both gave this stance up. Nick of TSSD, saying roughly, my eyes are going, and the bigger size is better for me. Now most except them being called 60mm, or the new 1/32. I read from time to time from posters, "People are different sizes, so the different size figures are fine. My problem with this position, is that the equipment worn, helmets, weapons, are not different sizes. The kits, helmets (for most armies), and rifles are the same size, no matter the size of the person holding them. So for me personally, some lines i just can't mix. Expeditionary Forces WWII guys, way out of scale for my other WWII guys. So how to measure, Top of the head, to the bottom of the foot of a figure. I would say in the past, the base was included in the measurement, with most being just a flat shape underfoot. Some like Atlantic, have a fatter base that distorts, but still is a flat suface that the figure is standing on. Now, most have some sort of a detailed, textured base, so i would say measure head to toe. In the case of the figures that prompted this thread, to me the two aren't too far off, easily live in the same world, the partisan could be a youth, or a shorter adult
