They can differ from the point of (specified) Height being evaluated to any given time during the (ongoing) rendering process.
From MSDN:
There is a difference between the
properties of Height and Width and
ActualHeight and ActualWidth. For
example, the ActualHeight property is
a calculated value based on other
height inputs and the layout system.
The value is set by the layout system
itself, based on an actual rendering
pass, and may therefore lag slightly
behind the set value of properties,
such as Height, that are the basis of
the input change.
Because ActualHeight
is a calculated value, you should be
aware that there could be multiple or
incremental reported changes to it as
a result of various operations by the
layout system. The layout system may
be calculating required measure space
for child elements, constraints by the
parent element, and so on.