Mostly I meant, if no one is actually penetrating anyone, do you still label one actor as top, or not?

I've had a lot of problems showing who tops in my stories because a lot of them have twists

Yes! Because I'm not into writing the formula sex--both of them top, or neither of them top according to the way folks look at things, but if there are only blow jobs and Sam only blows Dean who does not reciprocate, what does that mean? Does that make Sam the top because he was the aggressor?

So confusing!