of the appraisal within the period described in clause (i)(I), file an amended return for such taxable year with respect to any adjustment in taxable income as determined pursuant to subclause (II). (II) Adjustment of taxable income With respect to any taxpayer who elects to provide an estimate described in subclause (I)(aa) for any taxable year in which a timber casualty loss occurred, the taxable income of the taxpayer for such taxable year shall be increased or decreased, as applicable, by an amount equal to the difference between— (aa) the appraised value of such uncut timber determined immediately before such loss was sustained, as determined pursuant to the appraisal described in clause (i), and (bb) the estimate provided by the taxpayer under subclause (I)(aa) with respect to such uncut timber. (C) Exclusion of timber not held for sale Subparagraph (A) shall not apply to any timber unless such timber is held for the purpose of being cut and sold in connection with a trade or business that is not a passive activity within the meaning of section 469. (D) Inclusion of pre-merchantable timber For purposes of this paragraph, the term uncut timber shall not fail to include pre-merchantable timber. (E) Reforestation requirement (i) In general Subparagraph (A) shall not apply unless the uncut timber subject to the loss is reforested (with hardwoods, softwoods, or any combination thereof) by planting, seeding, or appropriate site preparation, not later than the close of the 5-year period beginning on the date of such loss. (ii) Recapture The Secretary shall, by regulations, provide for recapturing the benefit of any deduction allowed under this section with respect to any uncut timber subject to loss to which subparagraph (A) applied if the taxpayer fails to comply with clause (i) during the period provided under such clause. (F) Other casualties For purposes of subparagraph (A), the term other casualty shall include loss of any uncut timber from— (i) wood-destroying insects, (ii) wood-destroying invasive species,