Ive only seen this happening as admin.
1. Make sub-forums
2. In Forum Option (CP) Untick Enable forum. Its still there?
3. Move that forum to a diffrent catergory and it disapears as expected. (Enabled= unticked).
More of a Heads up, if i have time i will test
to see if Joe public can see them as visable or not?
I did clear the cache but they were still visiable until
i moved them to the other catergory.