Toney Freeman does not have 23 inch arms. What you are seeing is the same old tape measure trick that bodybuilders have been using for years. Hidden from the camera on the other side of his arm there is about 2" of slack on the tape measure.
True 23 arms would be bigger in circumference than the average man's head. So when you see someone in a picture claiming to have 22-23" arms, compare them to the persons head in the picture. You'll clearly most are full of shit.