Pre-Atmos receivers are not able to decode additional information in the Atmos stream.
The AppleTV-version of Atmos (MAT2.0) is a special trick played on HDMI but it still needs an Atmos-capable receiver.
The only place I have seen a descripton of how MAT2.0 actually works, is here (obviously, there is no proof, that it is true or correct, just one insight):
Hi all, a few days ago Apple announced that it will make the entire catalogue available to stream with a new lossless codec, apparently up to 24bit/192kHz. Apple Music announces Spatial Audio and Lossless Audio If this is coming to Apple TV and its able to feed that through the HDMI cable...
www.martinloganowners.com
Sending Atmos' 16/48 stream over HDMI as 16/192 actually quadruples the amount of bits sent. But the AVR needs to understand this LPCM's fake sampling rate and must compensate during MAT2.0 decoding process.