Mine is 24" tall, and I've never had a problem. My Yorkie is a young, 10-pounder who's been in agility, but 24" is too ambitious for him to jump.
I believe I did read where a Yorkie climbed a 24 incher, but I think that's rare.
So if you want to be cautious, go with 36, but I think 48 would be overkill.
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