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.
It would display the same if there were no HoldForm on the 10. The same is true of the 6. Note that the HoldForm around the 6 disappears in the next step. Are you saying that every part of Trace is automatically wrapped in HoldForm, whether it is needed or not?