I know the Rubicons came with 31 tires, and there seems to be room for more. But if you don't trim, say for like a 33 tire, you wont be able to flex the suspension a lot without rubbing on something.
i wanna say 33 inch mud terrains. with minor minor trimmings. not bumper trimings. i fit 33's on my grand cherokee w/ minor trimming and wranglers have the best tire clearnce.