Tammy has an apartment in addition to her principal residence. She acquired the apartment many years ago for $150,000 and it is now worth $480,000. She is worried that it will continue to appreciate in value and that the resulting income tax on the capital gain could erode her estate upon her death. She wants the property to go to her daughter, Doris. Tammy decided to sell the property to Doris now for its current fair market value. However, she told Doris she could pay her in 12 equal annual installments of $40,000, beginning in the year of the sale; the first installment would be paid at the time of sale. How much can Tammy claim as a capital gains reserve in the year of the sale?