Not unusual?
Now, you asked—if his verbal instructions were properly received—“as to what are the amounts that need to be recorded as a charge against the appropriation”. He didn't give a philosophical answer; he zeroed right in on this one particular point of $23 million, and then came up with a point, a highly technical rationale, to say “not appropriate”.
The legal point of view you requested was a broad-based question “as to what are the amounts needed to be recorded”? So he didn't give you what you asked for. Why? Why did you accept this?