If you can take the transfer case out of gear, you should have no problem. I had one and towed with the gear lever in the Park position so that the transmission does not rotate. In act all auto towing is done this way, with few exceptions.
What Bob said.
I've been flat towing a Wrangler for 5 years. Either put it in 1st(manual trans) or put it in park(Auto)
Put your transfer case in neutral and you're off.
I have always had the fear that I forgot something and still, to this day have my son stand in the back after I 1st hook it up to make sure that it is rolling free.