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**Function parameters should _not_ be allowed to be used in place of a return value.**

Reasons:
- Terms like _return value_ and _function result_ are explicitly specified as a specific, formal language item in most languages. 

  Therefore, interpreting a challenge asking for a return value as "return through parameter" is creating a local code golf dialect of the language (as was done on Stack Exchange). 

  New users of the site should not need to study local, site-specific dialects of programming languages in order to contribute. It's bad enough to allow non-standard extensions.
- Not all languages support pass by reference.
- Some languages separate subroutines (do not return a value) from functions (returns a value).
- Assuming that things like memory allocation are handled by the caller might give contributions an unfair advantage.