"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."

The buyer and seller have to agree on what was actually purchased so see what happens when the buyer has a chance to review the 8594.  If you get a blank form back with a note saying "oletko hullu", you know there are still some negotiations to be done.