Ive seen it done on HuluD44's build. he made one on his TJ from what i believe was the stock tailgate tire carrier and some angle iron to raise it off from the floor.
this isnt his but I found a similar one
2004 WJ I6 4.0L DD
1987 YJ I6 4.2L Weber 34 DGEC carb, 4in RC, Custom 1 inch BL,Custom Steering box skid, homemade rear bumper with tire carrier, 33x12.5x15 KM2's on
Cragar Soft 8's, and a few other things
In the process of putting in an 8.8, d30, 4.10's, SOA, and a homemade belly up skid