If I got notice from the IRS saying I owed $50 in back taxes, I'd just pay it. It wouldn't be worth my time or effort to fight it. I certainly wouldn't be wasting my time or effort to fight $50 worth of income disputes.
My point is not whether or not I would pay it (of course I would).
My point is that the Government can keep track of hundreds of millions of taxpayers down to the penny, but they can shrug their (collective) shoulders and say “we can’t say for sure what happened to $2.8 billion.”