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I develop plenty of custom themes, but they're 1-offs for my clients.
I don't develop any custom themes for resale. I think the biggest pitfall would be the constant updates and support. In order to keep sales up you'd need to be on top of all support questions/requests, and you'd need to release updates to the theme every few months as WordPress changes and newer best-practices come into standard.
It's something I've thought about, but just don't have the time or desire for.