Bad tombstoning support shouldn't cause a marketplace certification fail.
The only related thing I can think of would be if a lack tombstoning handling caused a crash or the app to be left in an unusable state. (Possibly a blank screen with no refresh button.)
Handling for tombstoning means making sure that if the user leaves your app and the returns to it, via the back stack, the app is in the same state (as far as is appropriate to the app) when they return as it was when they left.
There is a helper library which you may find useful: http://tombstonehelper.codeplex.com/ (I wrote it)