I would believe that if the wheels are off the ground and you start the car in neutral that it would be possible for one of the wheels to start turning. Your engine is still turning the TC and all the fluid going through it. This circulation may be enough to break the static friction of the front tires.
....or not
Actually my dad's 1969 Nova will almost move if he snaps the throttle in neutral. He has a huge 4400 stall TC installed though.