50
Opinion of the Court
ground principle. Cf. National Private Truck Council, Inc. v. Oklahoma Tax Comm'n, 515 U. S. 582, 589-590 (1995); United States v. Shabani, 513 U. S. 10, 13 (1994). That is doubly true when it is enacting limitations periods to be applied by bankruptcy courts, which are courts of equity and "appl[y] the principles and rules of equity jurisprudence." Pepper v. Litton, 308 U. S. 295, 304 (1939); see also United States v. Energy Resources Co., 495 U. S. 545, 549 (1990).
This Court has permitted equitable tolling in situations "where the claimant has actively pursued his judicial remedies by filing a defective pleading during the statutory period, or where the complainant has been induced or tricked by his adversary's misconduct into allowing the filing deadline to pass." Irwin, supra, at 96 (footnotes omitted). We have acknowledged, however, that tolling might be appropriate in other cases, see, e. g., Baldwin County Welcome Center v. Brown, 466 U. S. 147, 151 (1984) (per curiam), and this, we believe, is one. Cf. Amy v. Watertown (No. 2), 130 U. S. 320, 325-326 (1889); 3 J. Story, Equity Jurisprudence § 1974, pp. 558-559 (14th W. Lyon ed. 1918). The Youngs' Chapter 13 petition erected an automatic stay under § 362, which prevented the IRS from taking steps to protect its claim. When the Youngs filed a petition under Chapter 7, the three-year lookback period therefore excluded time during which their Chapter 13 petition was pending. The Youngs' 1992 tax return was due within that three-year period. Hence the lower courts properly held that the tax debt was not discharged when the Youngs were granted a discharge under Chapter 7.
Tolling is in our view appropriate regardless of petitioners' intentions when filing back-to-back Chapter 13 and Chapter 7 petitions—whether the Chapter 13 petition was filed in good faith or solely to run down the lookback period. In either case, the IRS was disabled from protecting its claim during the pendency of the Chapter 13 petition, and this pe-
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