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You can comment out the activate and the problem persists.

Its that there doesn't seem to be any menubars exposed in this context.

This script displays 1 when run from the script editor, but 0 when run as a toolbar script.

Code:
tell application "OmniFocus"
	tell application "System Events" to tell process "OmniFocus"
		set x to every menu bar
		set y to (count of x)
	end tell
end tell
display dialog y

-P