That's always made sense to me as well; I just can't figure out why the Jeep manual says you can't tolly tow any of the Jeeps with a standard transfer case such as a TJ or JK.
It could be that Jeep doesn't advise it because there will always be that guy that takes off in his motor home towing his Jeep in gear and not realizing it ( my Dad did this). A diesel pusher doesn't even feel a dragging Jeep back there. Instead of possible warr. issues they advise not doing it. Who knows, but I do it, and when you think about the mechanics of it there is no reason not to flat tow or dolly it.
'05 supercharged LJ Rubicon 6-spd, 4 speed Atlas, 6" Teraflex LCG pro, HP 60 front, Tera 60 rear, 5.38's, arb'd, full Tera skids, Raceline bead locks, 40" MT/R's, full cage, OBA, etc...