satisfying the safe harbor to avoid a penalty for the underpayment of estimated tax, and (7) if the Secretary determines appropriate to carry out the purposes of this section, provide for the separate application of such sections with respect to different classes of assets. (k) Standards for making certain determinations For purposes of making any determination described in subsection (e)(2)(A), (e)(2)(B)(iii), (e)(3), (f)(2)(C), or (f)(2)(D), the Secretary shall balance the goals of ensuring valuation accuracy, minimizing the potential for taxpayer gaming, and avoiding unduly excessive compliance and administrative costs. 1482. Certain otherwise exempt transfers by certain wealthy taxpayers treated as taxable (a) In general Notwithstanding any other provision of this title, in the case of any specified transfer by a covered taxpayer, gain shall be recognized by such covered taxpayer in an amount equal to the excess (if any) of the estimated value (as defined in section 1481(e)(2)) of the property transferred over the adjusted basis of such property. (b) Specified transfer For purposes of this section, the term specified transfer means any gift, charitable contribution, bequest, or other transfer upon death. (c) Covered taxpayer For purposes of this section, the term covered taxpayer means, with respect to any taxable year, any taxpayer which is an applicable taxpayer for such taxable year or was an applicable taxpayer for any of the 10 taxable years immediately preceding such taxable year. (d) Regulations The Secretary shall issue such regulations or other guidance as may be necessary or appropriate to carry out the purposes of this section, including regulations or other guidance that provide for exceptions with respect to— (1) transfers which are de minimis or which otherwise do not pose a risk of circumventing the purposes of this chapter, and (2) taxpayers which do not pose such a risk. . (b) Credit against taxes on recognized gains Subpart A of part IV of subchapter A of chapter 1 of the Internal Revenue