There's a difference between "can" and "should". 15-20 is probably an ideal upper limit, but you can fit lots more if you have to.
For example, One of my 10G quarantine/treatment tanks has 19 guppies (temporarily!) in it. Ammonia/nitrite is staying at zero, nitrate is increasing a bit faster than I'm comfortable with, but that is to be expected since the fish produce more ammonia while being medicated (or stressed) and there is less water to dilute the nitrate end product.
I was expecting the antibiotics and the fish overload to knock the filter back a bit and so I was testing the water twice a day. Oh, and its got a maximum dose of coppersafe in it too, which is another mild bio-filter inhibitor.
Anyway, the fish have improved dramatically since I started the antibiotics. I collected two other unwell fish from my other tanks to give them the benefit of the treatment as well, and all but one have had specacular recoveries.
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