True. When Naruto first summoned Gamma he was in a life or death situation, so he had to call out the 9 tail's chakra to do it, plus his own chakra was probably still pretty low from his training. But in the fight against Gaara it was his desire to save Sakura that he was able to muster enough of his own chakra to call Gamma again, even though he had beat Neji a few hours earlier he had plenty of time to rest for his chakra to return to normal level.
So up till he left for training the only way he could summon a high level toad like Gamma was if he was in a life for death situation or someone he cared about was in danger. Up till then he ended up with a tadpoll or a small toad every time he tried.
But Training with Juraiya all that time he had to have worked on his summoning technique more. But I'm just wondering how much he improved his summoning. Who knows. Maybe he'll summon something during the fight with Tobi.




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