This is probably of no practical importance but my curiosity is aroused. For example, the end result of Trace[2*3+4] is HoldForm[10]
tr = Trace[2*3 + 4] TreeForm[tr]
Sure, why bother to test if HoldForm is needed or not?
It's like going to the grocery store to buy a bag of chips and the salesclerk puts the bag of chips in a plastic bag.
No thinking required.
See below.