I'm 6'6" and 250 pounds, I've got 3 bikes that I beat up like they owe me money, and not a one of them has 36h wheels.
The key isn't always more spokes, it's properly built wheels. Most of my wheels are handbuilt (by me) 32h mid-section rims (DT RR1.1, Wolber Alpine T170, Alex DA16, Mavic Open Pro) laced 3 cross with DT Champion 2.0 straight gauge spokes.
Properly tensioned and stressed during the build process, a 32h wheel should hold true and round for you for thousands of miles.
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"I feel like my world was classier before I found cyclocross."
- Mandi M.