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So your whole argument is that Nagato couldnt use all six paths in that battle cos he hasnt learnt them but Madara can use all six paths cos he's already used one? You're making so much sense.he can use preta, it is implied that he can use all.
Two reasons:
1) he couldn't use all six paths
2) Same reason he didn't banshou tennin konan to safety. PIS
PIS, since he used shinra tensei in the battle already.
And ignoring points goes both ways my friend. The fact is that Tobi just received the rinnegan and has the ability to do things nagato couldn't do after years of training (make the six paths), and can already use all of the six paths himself.
So the curve stops at learning the six paths, that is the highest mastery of the rinnegan. Unless of course the manga reveals in the future that there are other techniques that have yet to be learned.