There's other whitespace in there that does get counted - for example, LOC is different depending on whether you prefer K&R braces. And since comments compensate for things that code doesn't directly express, it probably makes sense to include them too.
If we're trying to measure code complexity I think we have to ask "complexity to whom". If it's to humans, we should measure the code as it appears to humans. If it's to machines, then "line" is meaningless and we should look at tokens, the way PG suggested years ago.
If we're trying to measure code complexity I think we have to ask "complexity to whom". If it's to humans, we should measure the code as it appears to humans. If it's to machines, then "line" is meaningless and we should look at tokens, the way PG suggested years ago.