Maybe. The 10% is of the entire purchase price. The 26% is only the capital gain. Gain could be zero or there could be a loss. I thought your original $1,320,828,000 sounded low, but at least you had data. Too many on this thread and others post what they "feel", not what they can prove.
Is it? I seem to recall that it's 10% of the estimated capital gains, but I haven't looked in a while...