I used Paypal to send ebay art and I did not use tracking. Buyer had purchased the year before too. I received an email from her that she loved the 2nd purchase just as much as the first. THEN same buyer reported to paypal that it was a fraudulent purchase on her account. When I emailed her to ask what was up and had she made a mistake?..she told me that it was a virus that got on the computer, and this virus did it to all of her purchases and she had contacted paypal to clear it up.
I sent all of these emails as proof to paypal who STILL gave her money back to her and I got a chargeback fee to boot! They sent me an email saying “We did not receive proof of shipment.” ALL BECAUSE I DID NOT USE TRACKING!
When I emailed buyer again to tell her they charged me, never heard from her again.
Use tracking every time.