This got me to wondering what happens with donations of airline miles to a charity.  Does it not qualify because it's only good for a partial interest in the seats on one plane for a limted time?  Here's what the Make-A-Wish Foundation says:

Tax Deductibility
The IRS recognizes award points and miles as a gift or an award from the corporation to the individual. Therefore, points and frequent flier miles donated to charity are not considered tax deductible.

With all due respect to Make-a-Wish (one of its founders is the son of one of my clients until she passed away) that is a non sequitur.  If someone gives me a gift, and I decide to pass it along to charity, I can still deduct its FMV.  And what happened to all the IRS propaganda that airline miles are taxable ("we're just not going to enforce it")?