This is more of a philosophical question than anything, so give me your thoughts.
The iPhone SDK documentation specifies that you may have a tab bar controller conta
I can see where they are coming from, from a design perspective. Tabbars feel anchored, constant, where navbars feel dynamic and mutable. So a tab containing dynamic content makes sense, whereas a single spot in the dynamic hierarchy of a navigation stack containing a tab bar, anchored to the bottom of the screen doesn't feel as right. The Three20 implementation does handle this in a way that makes more sense, anchoring the tabs underneath the nav bar, so that they feel more like they are part of that spot in the navigation stack.
Having said that, Tweetie rolls it's own tab bar, if I remember correctly, without a UITabbarController to circumvent this detail in the UI guidelines, and it totally works from an interaction perspective.