The primary issue is that there's a chance that the T-34's wheel and then fuel tanks can block the shells which probably is partially caused by the fact that wheels are basically a 20mm RHA plate with no modifier.
https://steamcommunity.com/app/1498130/discussions/0/601905718689351544/
Game version: 1.0.10
Video (the non penetration shots happened after ~2:00):
https://www.youtube.com/watch?v=A3RR1QUHNe4
This topic might be worth checking:
https://forum.il2sturmovik.com/topic/52059-the-original-data-and-analysis-of-t-34-85-protection-and-firepower/
Edit.
This probably as well
https://forum.il2sturmovik.com/topic/52058-the-principle-of-armor-piercing/
Also included an image as a reference in case the KV-1 has any issues