Yes, provided you use up-to-date SGML software which knows about the WebSGML Adaptations TC to ISO 8879 (the features needed to support XML, such as the variant form for EMPTY elements; some aspects of the SGML Declaration such as NAMECASE GENERAL NO; multiple attribute token list declarations, etc). An alternative is to use an SGML DTD to let you create a fully-normalised SGML file, but one which does not use empty elements; and then remove the DocType Declaration so it becomes a well-formed DTDless XML file. Most SGML tools now handle XML files well, and provide an option switch between the two standards.