Lance has the goods on you here Sean. That 38,000 figure was for the 260 series U-joint used in a Dana 30.
I don't think there's much doubt in anyones mind (except for a few die hard Toy loyalist who will fight to the end) that a standard CJ Dana 30 and a Toy front end are pretty much equal. The dana 30 ring gear is 7.5" and the Toy ring gear is 7.8". The u-joint and birfield are the weak points, and both are the same strength. You can talk about putting in the Toy v-6 8.2" ring gear, but that doesn't change what the weak point of the whole asembley is.
Toy front axles really start to lose once you start discussing the reverse rotation Dana 30s used in YJs and XJs, especially with the 297 U-joints. Like Lance said, the breaking point for a 297 series U-joint is around 56,000 to 60,000 in lbs, but in all fairness the marfield also checks out at this strength. The difference here is that the marfield was never offered from the factory, while the 297 U-joint was offered in many YJ, XJ and Grand cherokee Dana 30s from the factory. The 7.5" ring gear in the reverse rotation Dana 30 is also around 25% stronger than a standard rotation ring and pinion of the same size when used in a front end application. The later YJs and XJs have it all over Toyotas for front end strength.
Then there's the housing issues. The open knuckle construction of a Dana 30 is far superior to the Toy closed knuckle design. Dana abandoned closed knuckles around 1970 to increase turning radius and help seal things better.
We won't even bother getting into specifics with Dana 44 fronts, they are so much better than a toy front end that it's not worth arguing about. Toyota just plain won't offer anything that's close. Would you put a Toyota axle in the front of a full sized 3/4 ton truck? Ford, Dodge, Chevy and Jeep all used Dana 44s in the front of 3/4 ton full sized trucks. Even to this day you can still get a Dana 44 in a new Dodge 2500.
Here in the world of Jeeps we are a group of guys that will use whatever part is stronger when we upgrade our trucks. Take a look at some built CJs and you will find all kinds of Ford, Chevy, Scout and Jeep Wagoneer parts. You won't find many with Toy front axles though. This is becuase we chose the strongest parts when we upgrade, with no regard to the original donor vehicle. This has made a lot of Scout II owners hate us for using their parts up, but Toy owners will have to find another reason to hate us. You'd see a lot of Toy front ends on CJs if they were an upgrade, but for some reason no one uses them. It's not becuase a Scout or Wagoneer front end is a perfect fit either, both are about three inches too wide, but we find a way to make them work becuase they are the best choice short of a Currie reverse rotation 9" (which still uses Dana 44 outers) or Dana 60 front end.
Botom line, you think what you want, and I'll think what I want. The information has been presented and now everyone else can decide for themselves.
I feel that I've proven my point and I'm not going to bother with this thread again. The numbers speak for themselves.