Theoretically, yes, 2-Lo has the potential to send double the torque and damage the axle.

But just think, no matter what, your torque here is limited by your traction. As long as you're just doing a burnout, I can put a 4:1 transfer case in 2Lo and still be safe.

Now if my rear tires are caught on something, like between rocks, or if I have drag slicks on, then we're talking snapped shafts and stripped ring gears.