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The inbox items don't participate in the sorting in Planning mode; the sorting operations are for the projects themselves with the inbox being a staging area. The inbox items aren't necessarily even comparable with one another -- some may become projects, some may become actions, some might be deleted and those that do survive processing will scatter across across your library into projects.

Hopefully the Inbox is small enough that finding things in it isn't a chore (textual filtering ignores the Inbox too!); if not, start processing! =)

(Note there is some argument to be made here that the Inbox might be large during your initial brain dump -- if you are finding this to be a trouble spot, please let us know via Send Feedback)
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CTO, The Omni Group