"Dylan Smith" wrote in message
...
It may qualify, but officially night IMC doesn't mean a clear moonless
night - that's still (officially) night VMC. Also, anywhere where there
is significant amount of lighting on the ground, night VMC (on a clear
moonless night, which is likely to also mean smooth flying conditions)
compared to a cloudy night with poor visibility (which may include
turbulence and icing in the clouds).

I was flying from Houston to New Orleans a year or so ago at night...
Technically, it was VMC, but from a practical standpoint, I was flying by
instruments... There was no moon and a high cloud layer that blocked view of
the stars... There were no lights on the ground because I was flying over
swamps... An interesting experience for a VFR pilot, but the air was
smooth, so the stress level wasn't that bad...