It could be the transfer case, driveshaft, differential. I'm sure there are other options that I'm not thinking about. How loud is the sound? Could you hear it with the windows up? Can you tell if the sound comes from the front or middle of the Jeep?
If you're planning on putting in a full locker in the front then I would likely take the gamble, and just try and get the seller to knock off a grand from the price. If you're lucky then it's just low on fluid, but if you need new gears in the front, and you need someone else to install them then it could be a thousand or two.