This is a nitpick, but early PC BIOS with C/H/S addressing could address up to 504 MB (1024 cylinders, 16 heads, 63 sectors) just fine. There was nothing stopping you from using a 32 MB drive, like the article implies.
What you did often run in to is that early BIOSes would only support fixed disk types, and not arbitrary C/H/S values. In some cases this would prevent you from using the full capacity of your hard drive when upgrading. 32 MB was a common early size, though, and would generally be covered by the standard disk types.
Dos before 3.0 used FAT12, limited to 16 MB, DOS 3.0 introduced FAT16 (though in a reduced 14 bit version) that extended size to 32 MB, DOS 4.0 had "real" 16 bit FAT16:
What you did often run in to is that early BIOSes would only support fixed disk types, and not arbitrary C/H/S values. In some cases this would prevent you from using the full capacity of your hard drive when upgrading. 32 MB was a common early size, though, and would generally be covered by the standard disk types.