One benefit of a cutting-grown tree is that if the tree dies back to the ground (from cold or a wayward lawnmower, e.g.) and the roots then resprout, the resultant tree will be of the desired variety, and not an inedible rootstock variety. It seems like grafted plants would be preferable in most contexts, though - better disease resistance, better climatic tolerances, better control over tree size, often better quality fruit, etc.... It seems like there has been a proliferation of cutting-grown trees at the big box stores here N. Florida, but I assume that is primarily because they are less labor intensive and therefore cheaper to produce. Approximately $20 is about the cheapest I have seen grafted trees retail for (excepting liners or discounted trees), but many of the cutting-grown trees are $16, or even $12 for the easiest to root varieties like lemons and limes.
Some suggest that trees growing on their own roots are more cold hardy than grafted plants - even as compared to those same varieties grafted on Trifoliata. If this is true though, it only seems to be true of seed-grown trees, and not cutting-grown trees.
