That's one possibility, another one might be that it's easy to write "is buried" when you meant "was buried" and can be hard to catch the error.
https://www.telegraph.co.uk/news/2017/04/10/quarter-christia...
However fact still remains that a huge number of people who consider themselves Christian do not believe in the resurrection, and that in itself makes it entirely reasonable to word things that way whether you agree that those people are Christian or not.