Cite as: 519 U. S. 347 (1997)
Opinion of the Court
"equitable tolling" exception. See 4 C. Wright & A. Miller, Federal Practice and Procedure § 1056 (2d ed. 1987 and Supp. 1996); see also Wolin v. Smith Barney, Inc., 83 F. 3d 847, 852 (CA7 1996) (defining equitable tolling).
In both cases, the Ninth Circuit read § 6511 as if it did contain an implied exception that would permit "equitable tolling." It then applied principles of equity to each case. It found those principles justified tolling the statutory time period. And it permitted the actions to proceed. 67 F. 3d 260 (1995); judgt. order reported at 70 F. 3d 120 (1995). All other Circuits that have considered the matter, however, have taken the opposite view. They have held that § 6511 does not authorize equitable tolling. See Amoco Production Co. v. Newton Sheep Co., 85 F. 3d 1464 (CA10 1996); Lovett v. United States, 81 F. 3d 143 (CA Fed. 1996); Webb v. United States, 66 F. 3d 691 (CA4 1995); Oropallo v. United States, 994 F. 2d 25 (CA1 1993) (per curiam); and Vintilla v. United States, 931 F. 2d 1444 (CA11 1991). We granted certiorari to resolve this conflict. And we conclude that the latter Circuits are correct.
The taxpayers rest their claim for equitable tolling upon Irwin v. Department of Veterans Affairs, 498 U. S. 89 (1990), a case in which this Court considered the timeliness of an employee's lawsuit charging his Government employer with discrimination, in violation of Title VII of the Civil Rights Act of 1964, 42 U. S. C. § 2000e et seq. The Court found the lawsuit untimely, but nevertheless tolled the limitations period. It held that the "rule of equitable tolling" applies "to suits against the Government, in the same way that it is applicable" to Title VII suits against private employers. 498 U. S., at 94-95. The Court went on to say that the "same rebuttable presumption of equitable tolling applicable to suits against private defendants should also apply to suits against the United States." Id., at 95-96.
The taxpayers, pointing to Irwin, argue that principles of equitable tolling would have applied had they sued private
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