44
Opinion of the Court
(b) Congress is presumed to draft limitations periods in light of the principle that such periods are customarily subject to equitable tolling unless tolling would be inconsistent with statutory text. Tolling is appropriate here. Petitioners' Chapter 13 petition erected an automatic stay under § 362(a), which prevented the IRS from taking steps to collect the unpaid taxes. When petitioners later filed their Chapter 7 petition, the three-year lookback period therefore excluded time during which their Chapter 13 petition was pending. Because their 1992 tax return was due within that three-year period, the lower courts properly held that the tax debt was not discharged. Tolling is appropriate regardless of whether petitioners filed their Chapter 13 petition in good faith or solely to run down the lookback period. In either case, the IRS was disabled from protecting its claim. Pp. 49-51.
(c) The statutory provisions invoked by petitioners—§§ 523(b), 108(c), and 507(a)(8)(A)(ii)—do not display an intent to preclude tolling here. Pp. 51-53.
233 F. 3d 56, affirmed.
Scalia, J., delivered the opinion for a unanimous Court.
Grenville Clark III argued the cause and filed briefs for petitioners.
Patricia A. Millett argued the cause for the United States. With her on the briefs were Solicitor General Olson, Assistant Attorney General O'Connor, Deputy Solicitor General Wallace, Bruce R. Ellisen, and Thomas J. Sawyer.
Justice Scalia delivered the opinion of the Court.
A discharge under the Bankruptcy Code does not extinguish certain tax liabilities for which a return was due within three years before the filing of an individual debt-or's petition. 11 U. S. C. §§ 523(a)(1)(A), 507(a)(8)(A)(i). We must decide whether this "three-year lookback period" is tolled during the pendency of a prior bankruptcy petition.
I
Petitioners Cornelius and Suzanne Young failed to include payment with their 1992 income tax return, due and filed on
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