I have to disagree - since prints ARE always viewed by reflected lights, the apparent tonal range IS the actual tonal range. The highest reflection densities I've ever seen on photo prints are about 2.40 (I know that PE likes to state lower numbers, but I've seen plenty of RA-4 media reach this.) I believe this maximum density is always limited by surface reflection, following the same laws as reflection from a glass lens. This unwanted reflection ultimately limits how dark a print can get.
Originally Posted by Michael R 1974
From what I've seen, photo papers have densities from about 0.10 (white paper) to 2.40, for a maximum net range of about 2.30. This is a range of about 200:1, in photographer terms, about 7-8 f-stops equivalent (an f-stop is about 0.30 density units). In reality, the situation is a bit worse, because we often see further reflections in the print (for example, try to hold a glossy black print so you can't see ANY reflection).
Any way you look at it, a negative film can easily hold much more greater tonal range than a paper print. So trying to fit the important parts of the scene onto paper is an important, and perhaps the most difficult part of the craft.