Cite as: 503 U. S. 638 (1992)
Opinion of the Court
follow our decision. We have no authority to limit the application of § 522(l) to exemptions claimed in good faith.
B
Taylor also asserts that courts may consider the validity of the exemption under a different provision of the Bankruptcy Code, 11 U. S. C. § 105(a), despite his failure to object in a timely manner. That provision states:
"The court may issue any order, process, or judgment that is necessary or appropriate to carry out the provisions of this title. No provision of this title providing for the raising of an issue by a party in interest shall be construed to preclude the court from, sua sponte, taking any action or making any determination necessary or appropriate to enforce or implement court orders or rules, or to prevent an abuse of process." Ibid. (emphasis added).
Although Taylor stresses that he is not asserting that courts in bankruptcy have broad authorization to do equity in derogation of the Code and Rules, he maintains that § 105 permits courts to disallow exemptions not claimed in good faith. Several courts have accepted this position. See, e. g., Ragsdale v. Genesco, Inc., 674 F. 2d 277, 278 (CA4 1982); In re Stani-forth, 116 B. R. 127, 131 (Bkrtcy. Ct. WD Wis. 1990); In re Budinsky, No. 90-01099, 1991 WL 105640 (WD Pa., June 10, 1991).
We decline to consider § 105(a) in this case because Taylor raised the argument for the first time in his opening brief on the merits. Our Rule 14.1(a) makes clear that "[o]nly the questions set forth in the petition [for certiorari], or fairly included therein, will be considered by the Court," and our Rule 24.1(a) states that a brief on the merits should not "raise additional questions or change the substance of the questions already presented" in the petition. See Yee v. Escondido, 503 U. S. 519, 535 (1992). In addition, we have
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