Actually slightly lower, 15/49. (The difference is like 0.15%.)
(I mainly mention this because I used to think my odds of drawing to a flush in poker were 1/4 per draw. It took me embarassingly long to realise that I needed to remove the cards I could see from the deck.)
I hadn't realised this, thanks.
> the three cards will never be the first cards out of the shoe
Does this matter? I'm using a model of "the dealer's other card is equally likely to be any of the cards except the two I have and his face-up one", and it doesn't matter where those three were originally. The model can be improved by counting cards, but it's still strictly (albiet very slightly) more accurate than the model of "the dealer's other card is equally likely to be any of the cards in the deck/shoe".
But perhaps there's something else about Blackjack that I'm not aware of?
You're correct about your other objections, and 15/49 is indeed harder to work with - but "without actually making it more accurate" is false under the one-deck assumption. It is not wholly accurate, but it is more accurate.
In blackjack there's a bet called Insurance which you can make if you have blackjack (21 in two cards) and the dealer has an ace. Essentially it's a bet that pays 2-1 if the dealer's second card is a ten/face, the odds of which are 4/13, making this the bet with the worst odds for a player on a blackjack table. But because it's called "insurance", a huge number of people take this bet.