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?

Name the exact Code section (proper citation format required), effective date, and applicable test (name and formulation) promulgated by the codification of the Economic Substance doctrine.