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Here's the use case:

I have a project -- maintenance for one of the web sites I manage -- at the moment it has no actions, but any moment, I could get a call from the client with something to do. I could mark it complete, and then create a new project for the new action, but I kind of like to bundle them when there are a bunch of small pieces -- update this page. Update it again later. Update it a third time. Each one of those is small and doesn't feel like it really deserves a "project". Also, that's how I bill them -- I bundle a bunch of these sorts of tasks over a month or two.

So I've got this container project, but at the moment it's empty. I'd like to get it out of the way. So I put it on hold. Then if I want to add a task to it, it makes the entry pretty laborious:

- switch to OF
- go to planning view
- switch to on hold projects
- find this project
- un-hold it
- switch to active projects
- add task

vs.

- bring up quick entry
- enter description, project, context
- use key combo to unhold project
- commit

Obviously, this isn't a highly necessary feature. Just a nice to have.