The same would be true of any part of the foot. If you somehow land on your heel and drag it out of bounds, that foot is considered in bounds because the foot landed in bounds. The toes aren't being treated any differently than the heel.
I get what your saying, and I'm sure that's the way the league sees it as well. However if you catch the ball drag your toes it's a catch. Even if your toes are still dragging the turf when you go out of bounds.
If any part of the foot lands out of bounds, then the player is out of bounds. His heel didn't have to come down in bounds, it just couldn't land out of bounds. If somehow he was able to keep his heel up, the toes in bounds would have been acceptable.
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