That is an interesting question. However is too difficult for a volunteer forum and it seems like it requires complicated legal analysis. The issuer clearly thinks it is such like stock, but gives no reasoning why and cites no legal authority. Issuers/promoters often think things that are beneficial to them. Relying on what you quoted (if it is wrong) will not get you out of accuracy penalties. For a very technical read in the area of what authority one needs see https://www.thetaxadviser.com/issues/2019/jan/substantial-authority-scorecard.html ... taxpayers (rather than tax professionals) may have a slightly lower standard, but I'm not sure of that and can't quickly find authority for that.
Before taking the position that they are like stock, you would be well served by getting a professional written opinion from a competent tax attorney. Especially if the amounts involved are not minor.
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