At least 20M civilians died in Russia during the war, not all by any means due to specific Nazi actions. The Reds also killed a many that they thought might be insufficiently supportive, and a great many died during the chaos of that most brutal war.
When I said 12M I was referring to civilians killed specifically in the "holocaust" referenced by the original author.
True, but it's hard to seperate the two. For example, most of the Holocust victims didn't die (or fall into Nazi hands) until the actual war started. Does this count the 2 million Soviet POWs the Nazis murdered from 1941-42?