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James Steadman, a taxpayer in the top federal income tax bracket, retires in 2016 and receives a qualified plan lump-sum distribution of $440,000. The pre-1974 portion of the distribution is $100,000. If James was born before January 2, 1936 and elects to treat the pre-1974 portion of the lump-sum distribution as long-term capital gain, how much tax would he pay on that portion?

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