(transaction did not constitute bona fide sale of ranch for corporate stock, but rather constituted corporate liquidation followed by distribution of cash to shareholders and payment to third party of a fee for facilitating sham sale; facts involved Wisconsin dude ranch in which shareholders wanted to sell their interests, but could only find a buyer for the operating assets; operating assets sold to LLC at $750,000 tax cost, but petitioner entered into "no-cost liquidation", a multi-step transaction consisting of nominal sale of corporate stock to facilitator followed by transfer by facilitator to shareholders of cash plus a premium; facilitator used bad debt losses acquired from other companies to offset gain on asset sale; transaction lacked economic substance).