License issues.
http://www.gnu.org/licenses/gpl-faq.html
Using only gpl code avoids them.
As well, applying a proprietary patch "taints" the kernel. This makes it difficult to get outside help should things go wrong. Like - don't go running to the kernel mailing lists.
You will be distributing it, so you need to give serious thought to how you will be licensing your patch. You also need to make sure the recipients understand how this works. It's a pain at first, but you get used to it - also, you end up more aware of the chains that proprietary vendors put on you, often without realizing it. Next thing you know, you're free... it's a slippery slope.
Oh: and "guru" just means I've made x-number of posts. I could as easily be "LQ Addict" but that's less cool