@sjrcpa 

When you stop to think about it, you realize how useless a 100% matching of Forms 8594 would be. Disclosure laws prevent IRS from telling one party what was on the other’s return. What you likely saw is a reference to this one audit project, which is listed among more than 20 others at

https://www.irs.gov/businesses/corporations/lbi-active-campaigns 

Practice Area: Western Compliance

“Parties that enter into taxable asset transactions under either IRC § 1060 or IRC § 338(h)(10) must report the transaction on either Form 8594 or Form 8883, which must be attached to their tax return. This campaign addresses LB&I business entities that either did not report a transaction on Form 8594 or Form 8883, or that reported the transaction inconsistent with the other party’s reporting of the transaction.”

So they will pull a few dozen returns, some of which should have had an 8594 but didn’t and some that did. Of those, if allocations look squirrelly they might pull the other party's return also. If this "campaign" leads to significant revenue, the audit selection process might be tweaked so that more business sales are examined. Like, 2 percent of them rather than just 1 percent.

My read on Section 1060 is that it puts the burden of proof on IRS, if the numbers match for buyer and seller.  But if you do a search for all Tax Court cases in which Form 8594 is mentioned, there are only seven since 1996.  The reference is often in a footnote, and matching does not appear as a factor.