tax, the deficiency shall be prorated to the installments payable under paragraph (1). The part of the deficiency so prorated to any installment the date for payment of which has not arrived shall be collected at the same time as, and as a part of, such installment. The part of the deficiency so prorated to any installment the date for payment of which has arrived shall be paid upon notice and demand from the Secretary. This subsection shall not apply if the deficiency is due to negligence, to intentional disregard of rules and regulations, or to fraud with intent to evade tax. (5) Election Any election under paragraph (1) shall be made at such time and in such manner as the Secretary shall provide. (6) Reduction of installment payments to extent minimum account balance is in excess of expected recognized gain If the minimum account balance of the taxpayer for any taxable year (reduced by the amount of any credit allowed under section 25F for such taxable year) exceeds 25 percent of the taxpayer’s net unrealized gain for such taxable year, such excess shall be applied to reduce the amount of any installment payments of the taxpayer the date for payment of which has not yet arrived (without regard to the taxable year to which such installment payment relates). Any reduction under the preceding sentence shall be applied to installment payments on a last-due, first-reduced basis. (i) Information reporting The Secretary shall, not later than 1 year after the date of the enactment of this section, issue regulations— (1) requiring such persons as the Secretary determines appropriate to file a return with the Secretary which include such information as the Secretary determines necessary to carry out this section, including the provision of applicable financial statements (within the meaning of section 451(b)), other financial or accounting statements, insurance valuations, or similar documents, and (2) requiring persons required to file returns under paragraph (1) to furnish statements to such other persons as the