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I think the best answer is to check the POH and placards in the aircraft. There are some aircraft that are well equipped with all required instruments and equipment that are still not certified for instrument flight. The Diamond Katana/DA-20 come to mind. They are composite and do not meet lightning strike criteria.
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My school just got a Diamond Eclipse, and it is the same way. I was all psyched sitting in it with my instructor, and I asked if we could take it on an instrument training flight. About the time I said that, I saw the big placard in the middle that says something like 'Approved for VFR flight only.' I started wondering why a school in FL would get planes that don't have lightning protection. I guess you COULD use it for IFR training, IF you remained VFR. It satisfies all the 91.205 requirements.