ent members of ZECC by reason of Zcash being a "marketable security" as defined in Section 731(c) of the Internal Revenue Code (the "Code")? Perkm Coe LLP -2- 139063133.3 EFTA00811131 3. Discussion (a) ZECC's Retention of the Founders Reward As an initial matter, ZECC, as a partnership for income