Sometimes, ob_get_level() may be off by 1 because at the start of the script, it will return 1 even if ob_start() has never been called (and clearing the output buffer via ob_end_clean() and the like can be done without error). As a result, the first ob_start() will have an ob_get_level() of 2, the second will be 3, and so on.
I'm not sure if this is a PHP 5 thing or [if it's related to when a] server is set to gzip all html documents.
Also, up until at least PHP 5.0.4 (current version), ob_get_level() will always return 0 inside a destructor. This happens because the garbage collection for output buffers has already done before the destructor is called. If you want to do something with the output buffer from within an object before the script exits, using a callback function with ob_start() is the way to go.