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I do believe the tag takes the top 5 salaries at the position and averages them, regardless of cap hit...which would make Sey's position a huge issue, as the top 5 salaries for DT are on average about 5 million less than the same for DE.
It's $6M for DTs and $9M for DEs, so it definitely is a pretty huge difference, but, as Synovia said, if you tag a player his salary has to be the average of the tops at his position *or* a 10% raise, whichever is greater, so no matter what position Seymour was tagged at, he would get a 10% raise over his current salary.