> basically a tiny header then the whole program in a big chunk.

This is inaccurate. A DOS .com executable has no header whatsoever. It is literally just the program code and data with absolutely no metadata at all. It is loaded at memory address 0x100 and then execution begins, also at 0x100.

It is possible to have a 0 byte .com executable and it will perform a useful function. 0 bytes are loaded to 0x100 and then execution begins at 0x100, effectively re-running the last program run. Commonly such a file was named "go.com".