It is not a ruling that simply managing your minerals and surface qualifies as trade or business income. It is not a ruling that managing minerals automatically removes royalties from portfolio income. Taxpayer owned minerals, working interests etc as a partnership and office with employees and wanted to be treated as trade or business and mix with other business income, most likely in order to deduct losses. IRS limited to Taxpayer’s claim to have particular circumstances which are not completely defined or explained. That will open them to self-employment taxes. Why would you want to do this?