Note taking can be deep and contain a lot of data (lists of items copied form CSVs, code snippets, documenting failures). Notes are more like code. You can spend your whole day in it - tweaking code blocks, refactoring, etc.
A lot of my sections are 5 tabs deep. Doing this with stars is harder to type, harder to copy/paste, and harder to read.
To be clear I cobbled together an example of what my notes may look like: https://gist.github.com/jonocodes/5574dc799774b4613c33d2572b...
I'm not even sure what tab level 2 should be in Markdown. Should it be a unordered list or a heading level 2? At what depth would I switch from headings, to lists, to plain text etc? I hit a wall pretty quickly with Markdowns restrictiveness here.