Well there are no rules as far as I know. If you're producing a normal popsong and you pan the toms in a random way people will throwing fish at you, but in jungle and house? I just produced a trance-track for a couple of Amsterdam dudes with a lot of 303's and 808's etc. I just panned my guts out. I don't believe its ever going to be listened to by not-stoned people so what the heck.
Back to real drum recording and panning. I justed to be moderate when panning drums etc, because your listening position in the studio is just in front of he monitors, and this will definetly screw up your stereo image. Panning a tom off-centre will result in hearing a tom off-centre. When listening to it at home or in your car etc. , this stereo image will be reduced because of the fact your not sitting right in the middle at 3 feet from your speakers. So the panning sensation will be drastically reduced. In the studio it's like looking with a (moment please, I'm going to get a dictionary).......... magnifying glass at your mix.
If you did a proper job with setting up the overhead mics and pan them hard left/right, they will give you a perfect stereo image. You can pan the close-mics you may have used on the toms to this stereo picture.