However, Walter Piston, writing in 1952, considered that, "a true thirteenth chord, arrived at by superposition of thirds, is a rare phenomenon even in 20th-century music.
"[4] This may be due to four-part writing, instrument limitations, and voice leading and stylistic considerations.
The underlying harmony during a thirteenth chord is usually Mixolydian or Lydian dominant (see chord-scale system).
[8] These voice leading guidelines may not be followed after the common practice period in techniques such as parallel harmony and in the following example: 13th chords may less often be built on degrees other than the dominant, such as the tonic or subdominant.
Generally found in root position,[3] the inversion of a complete thirteenth chord including all seven notes, itself, "a rare phenomenon",[4] is a theoretical impossibility since a new thirteenth chord with a different root is produced, for example Cmaj13 (C-E-G-B-D-F-A) becomes [disputed – discuss] Em13♭9 (E-G-B-D-F-A-C) then G13 (G-B-D-F-A-C-E), and so on, when inverted.