No, nibor, it is your analogy and assertions of law which is incorrect. And your three reasons are not the legal standard and you are attempting to create a test, exchangeability into USD or other funds denominated in the currency of a country, for the issue of what is a payment when there are already applicable tests in the USC. Last I checked it was Congress, not you, who created USC.

Payments, money transfers, designated payment providers and etc. already have established definitions under 31 USC 5362-5363 and terms like money transmitting service already have definitions under 31 USC 5330.

Under all of these definitions the common element is 'currency or funds denominated in the currency of any country'.

One issue relevant to this is whether bitcoins are funds? Currency or funds must be denominated in the currency of a country (31 USC 5330).

Airline frequent flyer miles, strings of text in a .txt file, PDF or Word files, ISK in Eve Online or other fictional units in games like Monopoly or World of Warcraft and Bitcoins are not denominated or redeemable (exchangeability is not a standard under the Code) in the currency of a country. Therefore, none of those mentioned nor bitcoins are funds.

One problem with attempting to legally define bitcoins, which probably will not even be attempted for years, is that any definition will likely fail constitutionality because of overbreadth or being void for vagueness. And there is always the rule of lenity.

Now, since bitcoins are exchangeable, like anything else individuals place value on, that is not to say that there are not tax implications when using Bitcoins, but those rules are governed under different code.