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Hmmm, well, not ALL zombies die from a shot to the head, some zombies in literature were headless remember, or they had a head, but their brain was missing.
Besides, that'd be a bit odd, shooting zombie hitler in the head and killing him just like that :P
I reckon it could be some sortof boss where you'd have to travel all the way up his office while he throws grenades at you and shoots at you, and once you get to his desk, you kick it over and it falls on him and crushes him or something.
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