Nesting <p> won't work while nesting <div> will?

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I usually won't nest <p> like this:

<p>The following:
    <p>one</p>
    <p>two</p>
</p>

and I will nest like that using <div> instead. But today I used <p> but it seems that both Emacs and Google Chrome both would consider the outer <p> closed as soon as it see a new <p> is started. (the DOCTYPE is HTML 4.01 Strict).

I thought <p> is no more than a <div> but just with some pre-defined margin and padding, but is it true that <p> cannot be nested? If so, what rule says that it cannot?

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