While I can't speak for AT&T, I can tell you that you can activate a phone as an internet device using WiFi only and shouldn't have to insert a SIM card to do that since it will use Wi-Fi.
Generally, carriers will force you to add a data plan if you are using a smartphone. Your best bet to find out would be to talk to an ATT representative.
Again, just having dealt with Verizon and T Mobile, I have used my Droid X as a wifi only device as well as my Galaxy Tab and not had to activate either of them through the network. They function quite well as wifi only devices.
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