That was exactly the reason the frame sizing method changed....
Bitd, when top tubes met the top of seat tubes, measuring c to c made sense.
But, come first drop top tubes then extended seat tubes, c to t made more realistic measurement.
Differing manufacturers measure to different points. Marin being a great example of a company who hung onto c to c for a long time.....hence all the bikes you see on ebay wrongly sized compaired with the catalogue.