If Koyomi is 165cm, she looks around 150cm in that picture, or around 4'11". That's not even that short by adult standards in Japan (5'2" or 158cm for 19 year old girls in 2006), and puts her in the same general size class as characters like Kei and Chihiro in EF.
I suspect the main reason she tends to get misidentified as a loli has to do with the her saying "You're all grown up, so you won't feel dirty looking at my body, right?" to Koyomi. Even I was wondering a bit after that.
She's thought process disruption inducingly cute regardless.
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Signature courtesy of Ganbaru.
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