pinniped

We've had long threads here about the value of miles and the various taxation cans of worms that can be opened in different situations.

Airlines benefit from the nebulous nature of miles. Miles aren't a currency, a promise, an asset, a financial instrument, a contract, or property. They kind of don't exist in a legal sense. Airlines can delete them, issue more of them, and change the rules about them at any time.

Therefore, I at least somewhat push back on the notion that they have tangible value in a legal property sense - of any kind. I mean, we all know roughly how we personally value the miles when it comes time to use them for awards. But our ability to use them for any value at all is entirely controlled by the airline, so sitting in my account they are literally valueless.

Of course, no one in the government is trying to make a case en masse that our trillions of collective miles are an asset with value that we have to report on our taxes. It just comes up in a few niche cases, like this charity one. And I don't know if anyone's ever effectively reported the miles as worth $0, and been contested by the IRS for doing so. And if so....what the ruling was. Feels like a Pandora's Box that the airlines definitely will NOT like if the government deems the miles as having a set value per mile any higher than a small fraction of a cent per mile.