Form 8594 is a tax document required in certain business sales where the buyer acquires assets rather than stock or equity. Both entities must submit IRS Form 8594 with matching allocations.Such alignment reduces audit risk. The seller and the buyer each use Form 8594 to allocate the assets among seven asset categories. Allocation is based on the fair market value. – Both the purchaser and seller are required to file Form 8594. – The Form 8594 must be attached to each filer's timely filed Federal income tax return. The Tax Court held that the taxpayer was required to take the assumption of the liability into income despite no corresponding deduction to the taxpayer. This article will help you understand the tax implications for both buyer and seller in the purchase or sale of the stock or assets of an Scorporation.