I quite often stumble over DNS entries without SOA.
In one of their more recent podcasts http://www.ask-mrdns.com/ the hosts Cricket Liu and Matt Larson have discussed the similar question what is the necessary minimum for a zone (file) to be valid. I believe it was around Episode 12 or so. If I remember correctly, they say a zone definition requires at least a SOA and one NS record, at least for BIND, in order to be valid.
May I suggest that you also send your question in to Ask Mr. DNS, as these two seasoned DNS experts are always keen on answering DNS-related questions in their podcasts.
Rolf