I spoke to my buddy that owns a tow company and he said put it in neutral also transfer case in neutral and if the rear drive shaft can be spun with your hand you are good but still the chance of it slipping out of neutral while in tow. He said only safe way is to pull the rear drive shaft. He said if the rear drive shaft is moving the transfer case will heat up..... he doesn't have a trailer and no time to get a tow bar so the Jeep stayed home.