To address a couple of quick misconceptions about epoxy resin (note, not epoxy paint) I'd like to quickly say that 1) it is not more expensive than pond liner and 2) it is flexible enough for plywood aquarium use. Epoxy resin is routinely used in industrial applications where flexibility is required.
But with that said, I do think pond liner is a valid consideration.
I know window attachment is a concern but I think there are enough long term liner tanks with windows to not worry about this too much.
Yes, pond liner is more flexible but epoxy is more than flexible enough.
A pond liner tank would allow for a modular design that could be moved. This is really only a concern at sizes that won't fit through doorways, around corners, down steps, etc.
Assuming the EPDM tape is as good as people report, liner tanks would be repairable and the floppy corners could be sealed up to prevent waste build up. An epoxy tank would be more infinitely repairable but unless one is really beating on a liner tank I think this is trivial.
As far as cost, epoxy can waterproof plywood at less than 30 cents a square foot. 45 mil EPDM Pond liner is around 70 cents a square foot and there is waste. In a two foot tall tank there would be at least 16 square feet lost to corners plus more lost to overlapping the top. There is the window cutout as well but at least you could use that for something. Not as useful as leftover epoxy, IMO.
A common tank size mentioned here on MFK is 8 x 4 x 2. Looking at Pondliner.com you'd need a 150 square foot liner for a tank that size.
But there is only 32 square feet for the bottom and and another 32 square feet for the back and sides. Window and top framing maybe another 15 square feet.
So in just that example you need almost twice the square feet of liner as you would epoxy. So even if you double up the epoxy and add fiberglass you're still only "using" about half the square footage that the liner would cover.
In reality most epoxy builds do and should use fiberglass resin. And most go thicker than the recommended 10 mils. So the cost does go up. Still, I think one could build a very strong, fiberglass reinforced plywood tank for the same cost as a liner sealed tank.