After trying several different combination of tags I haven't had any luck getting photoshop to open my frankenDNG files. I poked around a bit on the the Adobe site and found the DNG SDK supports just about everything you would want to do with a DNG and additionally sports a very liberal license.

It comes with an example implementation called dng_validate.exe.

So far every generated example that I try to validate gives me the following error:
Error: unable to find main image IFD

According to the README, the SDK supports both reading and writing DNG files. With the state of the DNG spec being as it is, the less frustraiting option is to just use Adobe's SDK.

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