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A owns all of the X stock with a basis of $200. A's three sons own all of the Y stock equally. X and Y each have E&P of $100, respectively. A sells one half of the X stock to Y for $200.
(a) What is the amount and character of income or loss to A on this transaction?
(b) Would your answer change if X, rather than A's three sons, owned all of the stock of Y?
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