(taxpayer, an LLC, seeks to form an entity that will be treated as a publicly traded partnership pursuant to I.R.C. Sec. 7704(b) (i.e., corporation tax treatment where the income from activities with respect to minerals or natural resources is treated as passive); entity will earn income by providing essential fluid, solids and other oil field waste handling, treatment and disposal services necessary in the fracking process for oil and natural gas extraction; such services to be provided through affiliated limited partnerships, LLCs or disregarded entities; IRS determined that entity's income from services provided would be qualifying income under I.R.C. Sec. 7704(d)(1)(E) as would associated income from marketing and distribution of salvaged hydrocarbons (but not income earned from marketing minerals and natural resources to end users at retail level).