Help! What Do You Make of This Table?

As I compare the 12th Virginia Infantry with other regiments, I see that something is wrong with this table.  Particularly with the 9th and 41st Virginia.  Maybe the H. E. Howard books on those regiments are wrong and low in their count of killed or mortally wounded.  Maybe Fox (Regimental Losses in the American Civil War) was wrong to think that the average loss in Confederate regiments was almost ten percent.  I counted the killed and mortally wounded in the roster of the 41st Virginia and was surprised to see that the number was so low.  The 41st went into action beside the 12th at Seven Pines and fought in practically all of the same actions as the 12th for the rest of the war.  On the other hand, in counting the 41st's casualties, I did not have the benefit of all the letters, diaries, memoirs and newspapers that I examined in writing a history of the 12th.  

Table 7:  The Petersburg Regiment (12th Virginia Infantry)Compared with Some Friends

            Readily available statistics exist for relatively few regiments in the Army of Northern Virginia, but the following suggest that within that army, the 12th Virginia may have been slightly below average.  It was slightly above average for the Confederate States Army as a whole, where the average regiment lost almost ten percent killed or mortally wounded.

                                                                        Killed or Died of                       Percentage

Regiment                                                          Wounds during War                 Lost during War

8th Alabama                                                     226*                                        15.9%*

9th Alabama                                                     142[1]*

7th North Carolina                                            179*

17th Mississippi                                                182[2]*

18th Mississippi                                                209*

42nd Mississippi                                               188[3]*

6th Virginia                                                       124                                            7.5%

9th Virginia                                                         73                                            3.8%

16th Virginia                                                       92[4]*                                         7.5%

41st Virginia                                                     105

12th Virginia                                                   159*                                        10.3%*

Average Confederate Regiment                                               “almost   10.0%”

* Meets criterion for inclusion in Fox’s Fighting 300 Regiments (130 or 10% killed or died of wounds).

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[1] An indeterminate number of others died of wounds.

[2] Numbers available for nine of ten companies; probably lost about 200.

[3] Up to March, 1865; probably lost around 200.

[4] The 16th Virginia fought with only seven companies.  Trask, 16th Virginia Infantry, 9.  The equivalent of 130 killed or mortally wounded among ten companies for a seven company regiment is ninety-one.

So was Fox wrong?  Or are the H. E. Howard regimental histories wrong?