A lower battery voltage does not mean a battery cannot handle a lower resistance atomizer or cartomizer. If anything, a lower battery voltage is generally preferable, as lower voltage means less current draw. What does matter is the current drive capability of the battery, and the maximum safe current for the electronics within the PV.
Fundamentally, the battery inside a PV has a maximum current draw rating,maximum discharge rate, the "C" number, where C is the capacity of the battery. If I have two 400 mAh batteries, one with a max discharge rate of 2C, the other with a max discharge rate of 5C, then the first battery can only provide a continuous 2x400 = 800 mA draw, while the second battery can provide sustained 5 x 400 = 2000 mA draw.
Now, many, if not all, PVs may go beyond that nominal C rating, since they are not really continuously "on", firing, but that gives a good starting point -- a battery with lower baseline C (capacity), or lower max discharge number before the C (say a 2 instead of a 5) is less able to drive a lower resistance.
The other aspect of low resistance, actually of higher current, is the current handling capacity of the electronics in a PV. Older eGos and Rivas, for example, had a MOSFET switch that was rated at 2 amps. Some MOSFETs could handle more current okay, but that was just due to production variability and engineering margin. That switch, and all of the voltage regulating stuff packed into the PV tube will have a maximum current rating -- driving beyond that rating may work, but it equally may lead to an early failure as you drive the electronics outside of their spec range.
Take a 1.7 ohm atty. Put it on an older eGo, driving 3.4 volts. 3.4/1.7 = 2 amps draw. You're within the spec of the MOSFET switch.
Take the same atty, put it on a 3.7V PV. Current draw = 3.7/1.7, or about 2.2A. If that second device has a 2A MOSFET switch it may work, but it may equally have an early failure.
Take the same atty, put it on a standard sized 180 mAh 510 battery, 3.4V. 3.4/1.7 = 2A, so the electronics may be fine if it has that 2A MOSFET switch, but since you've only got a tiny 180 mAh Capacity in the battery you are driving it very hard. You're pushing it at 11C (11 x 0.18 is about 2A), can expect to cook the battery, early failure.