The BeOS source is not clean. It had loads of third party closed source licensed stuff in the tree. It is also massive, it is a complete OS and most of the supporting apps source code. It would be non trivial to make it open and it would not compile cleanly as massive gobs of drivers and low level stuff (like font rendering engines) would be gone. And there are the unfortunate GPL violations. It would also need a lot of work to manage any opensourcing effort.
While I would normally make my "[citation needed]" joke, I'm sincerely curious about this. I can't find any references to this with an admittedly quick and cursory search. What were the violations?