Well, the important thing is that the drum is "in tune with itself". If the end result is that it turns out the drum is tuned dead on to a C or F or whatever, then great. But the note isn't the important part.
The size and depth of the drum is going to dictate its fundamental note. You don't need a tuner to find out what note it is. Just tune the heads properly and use your ears to find the zone. That will be the note of the drum. If you want to nudge it up a little if it turns out that note is flat or something, sure.. go ahead. But don't arbitrarily always tune the first tom to a certain key, the second, third, etc. Tune the drum to itself. After that, see how you like it. I bet no one will call you out and say "HEY, DRUMMER... I NOTICED YOUR SECOND TOM IS HALF A CENT FLAT OF E!"
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