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With the design of the sealed transmission with the tube that sticks up I understand now why people put the front wheels on ramps to drain out some of the fluid.
On our cars seems like a good idea if you are going to do a simple drain and refill to do it with the car "cold". That way assuming both the car and the new quarts of ATF are in the same garage, the ATF in the car is same temp as the new ATF you have in quarts to refill.