> The problem is that if this heading is called after a page
> break, including one inserted by the .ne call, the .sp 3.2i
> gets ignored, and everything is pushed up to the top of the
> page.

What macro package are you using?  My guess is that the
top-of-page macro sets the no-space flag, so the best
solution is probably to restore spacing (.rs) before
issuing the .sp.



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