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Apply has the problem in that Common Lisp allows compilers to restrict the number of arguments passed to a function to a small value (specified by call-arguments-limit: http://www.ai.mit.edu/projects/iiip/doc/CommonLISP/HyperSpec...).

I'm not well versed in CLHS legalese, but don't &rest arguments count as one argument? One would suspect so since &rest is allowed to be not copied.

Even if it is you still have to cons up all those arguments whereas reduce doesn't.