Usually it's 2 planes , one rotated at 90 degrees and placed in the middle of the first.1 Plane has one side and needs to have flipped normals so you can see its front and back,therefore when each plane is 2 polies,the total is 4 for 1 'tree' (2x2, or if you use more than 2 planes , multiply the number of planes by 2).
The reason I personally use 2 or more planes is because if you are looking at a plane at a 90 degree angle (or something very similar) it'll sort of disappear from sight.That's where the second plane comes into play.