According to Erica Sadun at TUAW, the iPhone can be used with an old SIM card. She activated her phone, then popped out the SIM card and put in an old one. The iPhone continued to function as an iPod, plus web and email via Wi-Fi.
However, I’m pretty sure this won’t work with an unactivated iPhone — and in the comments someone noted that it’ll likely get disabled when iTunes checks for a software update.