I'm struggling to understand this. You mean the 500 hPa temps are -28c? You want a large negative difference between the two and to be honest, you would use a lower down height than 500 hPa because no convective cloud top in winter will be that high.
Obviously a colder 500 hPa level implies also cold lower down at 700 hPa ish, but not always!
Edit: The post on the next page with the Herstmonceux tephigram illustrates this perfectly, big chonky inversions. To be honest, it's probably why 850s have become so widely used in winter, because it's roughly where cloud tops from convective easterlies will be, so you can have a rough guide to instability.