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 Code of 1986 is amended by inserting after section 25E the following new section: 25F. Minimum tax on certain wealthy taxpayers credited against recognized gains In the case of an individual (including any estate or trust), there shall be allowed as a credit against the tax imposed by this chapter for the taxable year an amount equal to the lesser of— (1) the taxpayer’s minimum tax account balance (as defined in section 1481) for such taxable year determined, in the case of any tax imposed under section 1481 with respect to which an election is made under such section to pay such tax in installments, by only taking into account so much of such tax as has been paid as of the close of such taxable year, and (2) the excess (if any) of— (A) the taxpayer’s regular tax (as defined in section 26(b)) for such taxable year, over (B) the amount which would be determined under subparagraph (A) if the taxpayer did not recognize any gain or loss for such taxable year. . (c) Refund of excess minimum tax on certain wealthy taxpayers Subpart C of part IV of subchapter A of chapter 1 of the Internal Revenue Code of 1986 is amended by inserting after section 36B the following new section: 36C. Credit for excess minimum tax on certain wealthy taxpayers In the case of an individual (including any estate or trust), there shall be allowed as a credit against the tax imposed by this subtitle for any taxable year an amount equal to the excess (if any) of— (1) the amount described in section 25F(1) for such taxable year, over (2) the sum of— (A) 25 percent of the taxpayer’s net unrealized gain (as defined in section 1481) for such taxable year, (B) the aggregate credits allowed under section 25F for such taxable year and all prior taxable years, and (C) the aggregate reductions