Rarity is relative. Every E107, for example, is a rare card but because so few people collect the set and most are happy with an example or two, nobody thinks of an E107 common as a rare card. But if there was a T206 with as few known examples as an E107 common- Wagner and Plank come to mind- then it would be thought of as a great rarity.
But no question the term is overused by sellers who mistakenly believe that if they call a common card rare it will sell for more money.
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