Just like for the 9" there are chromoly aftermarket axles for the 44 that are much stronger than the originals. Definitely want the highest spline count you can get for sure. The axle length in a Z is going to be significantly shorter than that in a 4x4, and that makes them stronger. One more comparison point. What are people putting through the 27 spline MM stub axles? Compare that to what they can put through a straight axle with a full chromoly 30 spline axle, with no CV joints. I think the D44 would be a lot stronger...
About your traction in dirt comment. I don't even agree about the traction thing if you're talking plain ol dirt. Think about the size of the tire. That gives it a LOT more leverage on the axle shaft itself than a smaller drag tire on a street car. But then you get into these rock crawling guys, who are BRUTAL on the diffs, and I would argue that they can put maybe 2 or 3 times the torque to the diff that a drag racer can. When the vehicle is on a 45º slope bouncing up and down trying to get over a big rock that's a LOT of stress on the axles. Whole lot of stress. Oh, forgot to mention that the off road truck is generally close to twice the weight of a Z.
Let me put it this way. I've seen a lot of diff carnage. The carnage I saw when I worked for Randy's Ring and Pinion was almost all 4x4 stuff. I'd say 90%. I've seen a driveshaft for a 4x4 that was twisted into a screw shape. I've seen axles twisted off at the carrier. Ring gears with 1/2 their teeth sheared off. Etc, etc. The stuff from the cars was usually a couple pinion teeth broken or the U-joints busted or burned up gears.
I still agree that a 9 would be the strongest build (with an upgraded 3rd member), followed by a 12 bolt, followed by an 8.8, followed by the 44. It's definitely not the strongest thing out there. I'm just saying that I think you're underrating the 44.