I have been towing a 1989 Toyota 4-Runner, v6, manual, 4-wheel drive, and the transfer case does not have a neutral position, for about 8 years. Of course, Toyota will not tell you that you can. I went and talked to 2 Toyota transmission mechanics and an independent transmission mechanic. Both of them told me that is was OK to tow, that the transmission would receive the same lubrication being towed as it received being driven. Toyota does not want to accept the liability so will not approve it. In my mind, the best advise comes from someone who is intimately involved in the workings of the transmission. If I remember correctly, I also talked to Remco and got the same advise.