Well. Theoretically.
- Comments do not have title field in a database. However they have meta natively, so quick
add_comment_meta()can get you title–like custom field. - Comments have links (
get_comment_link()), but they are heavily based on context of singular post displaying them. Displaying comments by themselves with their own URLs structure would take some creative rewrite effort. - I can’t say about level of effort it would take for taxonomies to work with comments, but it’s definitely not a natively supported object type for them.
In a nutshell you are going to be trying pretty hard to make comments behave like a custom post type and they just aren’t that. Although it would make sense, but WordPress, backwards compatibility, etc.
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