Because of the garbage collection algorithm. The .NET garbage collector works by periodically running through a list of all the objects that are currently being referenced by an application. All the objects that it doesn't find during this search are ready to be destroyed and the memory reclaimed. The implication of this algorithm is that the runtime doesn't get notified immediately when the final reference on an object goes away - it only finds out during the next 'sweep' of the heap.

Futhermore, this type of algorithm works best by performing the garbage collection sweep as rarely as possible. Normally heap exhaustion is the trigger for a collection sweep.