Ah regulatory consistency - wherefore art thou?
§ 91.167 Fuel requirements for flight in
IFR conditions.
(a) No
person may operate a
civil aircraft in
IFR conditions unless it carries enough fuel (considering weather reports and forecasts and weather conditions) to -
91.1 IFR conditions means weather conditions below the minimum for flight under visual flight rules.
§ 91.151 Fuel requirements for flight in
VFR conditions.
(a) No
person may begin a flight in an
airplane under
VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed -
(1) During the day, to fly after that for at least 30 minutes; or
(2) At
night, to fly after that for at least 45 minutes.
91.1 VFR means visual flight rules.
See:
https://www.law.cornell.edu/cfr/text/14/part-91/subpart-B
The phrase "IFR conditions" is defined. The acronym "VFR" is defined. The phrase "VFR conditions" is not defined.
So for the sake of legal nitpicking. What is the fuel reserve requirement for a pilot operating on an IFR flight plan in VFR conditions? I could argue that it is less than the fuel reserve requirement for operating VFR in VFR conditions.
Example. You have 30 minutes fuel in the ship. You want to fly from A to B ins VMC conditions. Flight time is expected to be 15 minutes. Are you legal to fly day VFR from A to B? No.
Are you legal to fly IFR from A to B IFR? Yes.
Is this careless and reckless (91.13(a))? Perhaps.