My client is a blogger.  She sold her website and a YouTube channel. No other tangible assets will be sold.  This is an asset sale. These 'assets' do not have any tax basis (as all costs were expensed in the past.)  Does that mean that the sales price is entirely for goodwill?

I think goodwill is the best result for my client as it is taxed at capital gain rates.

The 8594.  As I understand it, there is an inherent 'tension' between buyer and seller as the buyer will want assets to expense immediately while the seller wants capital gain treatment from goodwill.  I have completed F8594 and sent it to my client along with instructions for the buyer (who is in Finland) to sign it.