IRS ruling clearly indicates there are 2 possible ways of acquiring btc:
1) Mining: a taxable event that will be in your gross income based on fair market value of the mined coins. There will be another taxable event when you sell those coins, thus fall into capital gain.
That one sounds problematic. There are any number of reasons why the coins are not worth, in your mining machine that mined them, what any market happens to be offering for someone else's bitcoins already on that market at that time.
You might not even actually have any bitcoins by the time you actually go to move them off the mining machine to somewhere else, let alone by the time you actually get clearance at an exchange to exchange them.
So it seems unreasonable. Until you sell them you have no idea whether they are worth anything at all, they are a digital fiction that might someday turn out to be worth something but then again might not.
Same thing when you "farm" a magic sword or a pile of gold in World of Warcraft. Until you actually manage to sell them they are more a waste of time effort and money than any kind of gain, regardless of how many "exchanges" exist at which you hypothetically "could" sell them or exchange them.
Mining is like growing pork bellies, or milking cows, or growing wheat. Until you actually trade the stuff you won't know if it was worth anything at all.
For that matter how does mineral mining work?
Do coal mines pay tax each time a miner swings a shovel and mines another spadeful of coal?
In bitcoin mining I pour my capital into hardware and electricity (and hopefully into electricity-creating hardware) and someday hope to sell coins for more capital than I spend mining them.
-MarkM-