IME it seems like some fish are just dumb and refuse to school :duh: LOL, probably for the reason that winterwind suggested. However, in general it seems like 6 is pretty good, I think it helps when there is enough of them to catch each others eye and to encourage the schooling.
Another thing that will make a big difference is tank size, a group of 6 fish can't school very well in a 10 gallon tank, just because there isn't a ton of room for them. In a bigger tank they have more room to move around and are more prone to follow each other because the distance between them may be feet (in a bigger tank), as opposed to inches (in a smaller tank)