S-Corp Shareholder sells his insurance agency as an asset sale instead of a stock sale, but seller & buyer agree on a large Goodwill (L-T Capital Gain) allocation of purchase price.  Shortly after the sale his insurance agency is dissolved.  Can the shareholder take a $226k L-T capital loss on the $226k stock basis?

It is obvious that he could have used the stock basis if the transaction would have been a sale of stock.

I am assuming that he could still write off the stock basis in an asset sale.  

Thoughts?