When I first tried switching SIM's, I was forced to re-activate my old phone.
This is what I was talking about. You had to re-activate your first generation iPhone with the SIM card from your iPhone 3G, followed by contacting AT&T to switch your data plan back to the rate for the iPhone 3G. After doing these things, now you can use either iPhone with the same SIM card, but you are using the same line/phone number between the two.
This OP's situation is a little different - two different lines/numbers, and he is trying to fool the system making AT&T think his wife will be using the iPhone 3GS purchased at AT&T's subsidized or discounted price with her line/number followed by simply switching phones and SIM cards. This probably won't be a problem with a two line Family plan, but IMO it is probably better to contact AT&T about this in advance.